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Rachael Padgett

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Rachael Padgett’s practice focuses on the intersection of litigation and regulatory counseling, and she has a passion for advising clients on how to navigate product risk and achieve creative solutions.

As a counsel in the Litigation and Transportation Groups, Rachael handles matters involving product liability litigation, supply chain contract disputes, National Highway Traffic Safety Administration and Department of Transportation regulatory counseling, and Consumer Product Safety Commission reporting and investigations. With a focus on the transportation, micromobility, railroad, and retail product industries, she represents clients facing complex, high-stakes problems using a thoughtful, human approach to minimize client exposure and resolve disputes effectively.

Rachael maintains a pro bono practice with a focus on representing children in immigration cases and as guardian ad litem.

During law school, Rachael served as articles editor for The George Washington Law Review and received numerous awards, including the Jacob Burns Award for the First Place Team in the Van Vleck Constitutional Law Moot Court Competition, the Henry R. Berger Award for Excellence in the Area of Tort Law, and the Jennie Hassler Walburn Award for Excellence in the Area of Civil Procedure. She also worked as a judicial intern for the Honorable Michael O’Keefe in the Superior Court of the District of Columbia’s Family Court and regularly volunteered at the Family Court Self-Help Center.

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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

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

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

The National Highway Traffic Safety Administration (NHTSA) has published an updated proposed rule to amend its regulations to require recall notifications be sent to vehicle and equipment owners and purchasers by electronic means, in addition to first class mail. For more information about this rulemaking, see NHTSA Publishes Updated Proposed Rule on Manufacturer Recall Notifications