Vehicle Code 22102 CVC is the California statute that makes it a traffic infraction for a driver to make a U-turn in a business district, except at an intersection where it is authorized or on a divided roadway with an opening that allows for one.
A “business district” is an area where at least 50 percent of the property bordering the street is occupied by businesses and a driver can access them from the road. A violation of this law is an infraction that results in a traffic ticket and one DMV point.
CVC 22102 states that “no person in a business district shall make a U-turn, except at an intersection, or on a divided highway where an opening has been provided…this turning movement shall be made as close as practicable to the extreme left-hand edge of the lanes moving in the driver’s direction of travel immediately prior to the initiation of the turning movement…”
Examples of illegal acts
- driving through a Los Angeles business district and making a U-turn at an intersection with signs prohibiting it.
- making a left turn at an opening in a road and then making a broad left-turning movement to complete the U-turn.
- driving over a median to travel in traffic that is heading in the opposite direction.
A defendant can raise a legal defense to challenge an illegal U-turn ticket. Common defenses include showing that he/she:
- did not make a U-turn,
- was not in a business district, and/or
- acted out of necessity.
The offense is punishable by:
- a California traffic ticket,
- a fine of $238, and
- one point on the driver’s DMV driving record.
The DMV can do the following if a person receives a certain amount of points within a 1-, 2- or 3-year period:
- declare him/her a negligent operator, and
- suspend, or even revoke, his/her driving privileges.
Our personal injury and criminal defense attorneys will highlight the following in this article:
- 1. Is it illegal to make a U-turn in a business district?
- 2. Can I contest a 22102 CVC ticket?
- 3. What are the penalties?
- 4. What if I simply ignore the ticket?
- 5. What is the effect on a personal injury case?
- 6. Are there traffic laws related to this statute?
1. Is it illegal to make a U-turn in a business district?
California Vehicle Code 22102 says it is an offense if a person makes a U-turn in a business district.1
There are two exceptions to this general rule. A motorist can make a U-turn if he/she:
- is at an intersection that does not prohibit one, or
- is on a divided highway and is turning at an opening that allows a turn.2
A “business district” is different than a residence district. It is defined as:
- an area where at least 50 percent of the property bordering the street is occupied by businesses, and
- a driver can access them from the road.3
Note that if a driver makes a U-turn, he/she must make the turn as close as possible to the left-hand edge of the lane moving in the driver’s direction.4
Note also that this law does not prohibit a driver from:
- turning left across traffic, and then
- turning left again onto a street or driveway.5
2. Can I contest a 22102 CVC ticket?
Defense lawyers, and law firms, draw on several legal strategies to contest charges under this statute. These include showing that:
- the defendant did not make a U-turn.
- the defendant was not in a business district.
- the accused acted out of necessity.
2.1. No U-turn
This statute only applies to U-turns. This means it is always a defense for an accused to show that he/she made some movement other than a U-turn. Perhaps, for example, the defendant made a right turn or a left turn.
2.2. No business district
CVC 22102 only applies to U-turns made in “business districts.” Further, this term has a technical legal definition. A defense, therefore, is for an accused to say that:
- he/she did make a U-turn, but
- it was not made in a business district.
Under a necessity defense, a defendant tries to avoid guilt by showing that he/she had a sufficiently good reason to commit the crime.
In the context of this statute, an accused can attempt to show that he/she committed the crime because there was no other choice. Perhaps, for example, a driver had to make an illegal U-turn because of an emergency.
3. What are the penalties?
There are two penalties for violating this statute. These are:
- a ticket (usually in an amount of $238), and
- one point placed on the motorist’s DMV driving record.
The DMV can do the following if a person earns enough points within a 1-, 2- or 3-year period:
- declare him a negligent operator, and
- suspend, or even revoke, his driving privileges.
Note too that a traffic ticket can result in an increase in a motorist’s insurance rates.
4. What if I simply ignore the ticket?
A driver that ignores a ticket under these laws violates Vehicle Code 40508 VC. This is the State’s statute on the failure to appear in court on a traffic citation.
When a person is issued a traffic ticket in California, he/she has to sign a written promise to appear in court.
If the party willfully fails to appear as promised, he/she violates VC 40508.6 This is true of all traffic tickets, including tickets for:
- illegal U-turns,
- running a red light,
- driving over the speed limit, and
- crossing double yellow lines.
A violation of this law is a misdemeanor. The penalties are:
5. What is the effect on a personal injury case?
A driver that violates these laws may cause an accident with another motorist (e.g., in a head on collision or a T-bone accident). If the motorist is injured and later files a personal injury lawsuit against the driver, the driver may be found “negligent.”
In a personal injury action, a negligent party bears the responsibility for compensating the plaintiff for any injuries incurred.
- causing an accident, and
- doing so while committing an illegal U-turn in violation of CVC 22102.
6. Are there traffic laws related to this statute?
There are three laws related to illegal U-turns in business districts. These are:
- yielding when turning left and making a U-turn – CVC 21801,
- disobeying a sign, signal, or traffic control device – CVC 38300, and
- lane weaving – CVC 21658.
6.1. Yielding when turning left and making a U-turn – CVC 21801
Vehicle Code 21801 CVC is the California statute that applies when a driver is turning left or completing a U-turn to the left and is facing oncoming traffic.
The law says that a motorist in this situation must yield the right-of-way to approaching traffic up until he/she completes the turn with reasonable safety.
A violation of this law has the same penalties as making an illegal U-turn in a business district.
6.2. Disobeying a sign, signal, or traffic control device – CVC 38300
Vehicle Code 38300 CVC is the California statute that says it is a traffic offense for a driver to disobey any:
- traffic signal, or
- traffic control device.
These include things like:
- stop signs,
- traffic lights, and
- crosswalk signals.
Like with CVC 22102, violations of this law are charged as infractions.
6.3. Lane weaving – CVC 21658
Vehicle Code 21658 CVC is the California statute that makes it a crime for a motorist to weave inside a traffic lane or to straddle a marked line.
As with an illegal U-turn, this traffic offense can result in a ticket in the amount of $238.
For additional guidance or to discuss your case with a personal injury or criminal defense attorney, we invite you to contact us at Shouse Law Group.