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Rebecca Baden Chaney

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Rebecca Baden Chaney is a partner in the firm's Washington, D.C. office and is co-chair of the firm’s Transportation Practice. Transportation, micromobility, consumer, and other product manufacturers lean on Rebecca Chaney’s keen understanding of the transportation and consumer product industries and the legal landscape to advance their businesses. Rebecca applies her commercial-focused product risk lens to represent product manufacturers facing litigation, commercial, and regulatory challenges.

Rebecca is an industry-recognized force in litigating complex product-related warranty, defect, indemnity and contractual commercial disputes, and consumer litigation, including in class actions and mass tort proceedings. She counsels her commercial clients on product disputes, risk mitigation, and crisis management matters. Rebecca additionally defends clients against defamation claims. Clients appreciate Rebecca’s close coordination with them, her proactive approach, and her critical and creative thinking about each stage in a litigation or matter.

Rebecca’s approach embraces product liability risk management across the life cycle of product commercialization, from pre- to post-launch to aftermarket. This includes advice on product labeling, as well as National Highway Traffic Safety Administration and Consumer Product Safety Commission regulatory compliance, recall, and enforcement issues.

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On April 28, 2025, President Trump issued an Executive Order for Enforcing Commonsense Rules of the Road for America’s Truck Drivers. The EO declares it “the policy of [the] Administration to support America’s truckers and safeguard our roadways by enforcing the commonsense English-language requirement for commercial motor vehicle drivers and removing needless regulatory burdens that undermine the working conditions of America’s truck drivers.” Current Federal law provides that a commercial motor vehicle driver must be able to “read and speak the English language sufficiently to converse with the general public, to understand highway traffic signs and signals in the English language, to respond to official inquiries, and to make entries on reports and records.” 49 C.F.R. § 391.11(b)(2). A June 15, 2016, Federal Motor Carrier Safety Administration (“FMCSA”) guidance document describes circumstances in which that regulation will and will not be enforced. The new EO requires that the Secretary of Transportation rescind that guidance document within 60 days and issue new guidance with “revised inspection procedures necessary to ensure compliance with the requirements of 49 C.F.R. 391.11(b)(2).” Such guidance should ensure that “a violation of the English language proficiency requirement results in the driver being placed out-of-service.”Continue Reading New Executive Order on English Language Requirement for Commercial Vehicle Drivers

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On April 24, the Department of Transportation announced the Trump Administration’s new framework for the regulation of Automated Vehicles (“AVs”). To learn more, please read our Client Alert NHTSA Announces First Actions Under Trump Administration’s New Framework for Removing Regulatory Barriers for Automated Vehicles.

The National Highway Traffic Safety Administration (NHTSA) published the below notices of final rulemaking this month. Specifically, NHTSA published one correction to its recent final rule on child restraint systems, and two notifications of enforcement discretion announcing that it would not enforce the requirements of two of its new final rules until March 20, pursuant to the “Regulatory Freeze Pending Review” presidential memorandum. The agency did not take further actions on these rules after March 20 and they remain effective.Continue Reading NHTSA Rulemaking Roundup: March 2025

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The U.S. Department of Transportation (DOT) has rescinded Biden-era memorandums from the Federal Highway Administration (FHWA) that prioritized infrastructure projects with social justice and climate goals, aligning with the Trump administration’s policy direction. U.S. Secretary of Transportation Sean Duffy stated these memos lacked statutory basis and will no longer influence DOT programs. Critics of the earlier policies had noted that the policy prioritized infrastructure projects intended to maintain or upgrade existing roads, highways, and bridges rather than new construction. This will also give states more autonomy in prioritizing funding allocations.  Continue Reading DOT Reverses Course and Rescinds Policy Memos Related to Infrastructure Projects

The National Highway Traffic Safety Administration (NHTSA) published the below notices of final rulemaking in the Federal Register this month. Specifically, NHTSA published four delays of the effective dates of recent final rules following last month’s “Regulatory Freeze Pending Review” presidential memorandum directing agencies to further review final rules that have not yet taken effect. See below for brief summaries of the new rules’ extended effective dates.

Continue Reading NHTSA Rulemaking Roundup: February 2025

Our partner Amna Arshad is participating in the Grand Debate at The International Air Transport Association (IATA) World Legal Symposium 2025 in Shanghai on February 20! At the Grand Debate – the main event that closes out the conference – the panel will debate a matter of controversy in aviation law. Crowell International Dispute Resolution Partners Rob Hager and Michael Guiffre also are attending the Symposium.Continue Reading Partner Amna Arshad To Take the Main Stage at IATA Symposium in Shanghai

On December 30, the Department of Transportation announced 2025 updated civil penalty amounts for the following agencies:

  • Office of the Secretary (OST)
  • Federal Aviation Administration (FAA) 
  • National Highway Traffic Safety Administration (NHTSA)
  • Federal Motor Carrier Safety Administration (FMCSA)
  • Federal Railroad Administration (FRA)
  • Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Maritime Administration (MARAD)
  • Great Lakes St. Lawrence Seaway Development Corporation (GLS) 

Continue Reading DOT Announces Adjusted Civil Penalty Amounts

The National Highway Traffic Safety Administration (NHTSA) published the below notices of final rulemaking in the Federal Register this month. See below for brief summaries of the new rules and compliance dates for manufacturers.

  • Federal Motor Vehicle Safety Standards: Occupant Crash Protection; Seat Belt Reminder Systems; Controls and Displays (Jan. 3): NHTSA amended FMVSS No. 208 (Occupant Crash Protection) to extend existing seatbelt warning systems to: (1) require a seat belt warning system for rear seats, (2) update and enhance seat belt warning requirements for driver seat belt warnings, and (3) extend the requirements for driver’s warnings to the front outboard passenger seat. Manufacturers must comply with the front set belt warning system requirements by September 1, 2026, and the rear seat belt warning system requirements by September 1, 2027, with an additional year for multi-stage manufacturers and alterers.

Continue Reading NHTSA Rulemaking Roundup: January 2025

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President Trump’s “Regulatory Freeze Pending Review” Presidential memorandum, which asks agencies to consider postponing the effective date of any rules that have been published in the Federal Register but have not yet taken effect, could impact the new NHTSA final rule related to automatic emergency braking (AEB) technology.

The AEB final rule, published in May 2024, will require all new light vehicles to be equipped with automatic braking systems that meet certain performance requirements by Sept. 1, 2029. The “freeze” does not change this final rule or compliance date.Continue Reading Trump Administration’s Regulatory Freeze Memorandum Could Impact New AEB Rule