Vehicle Code 22102 CVC – Illegal U-Turn in a Business District

Updated October 7, 2020

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.

Penalties

Making an illegal U-turn is an infraction. This is opposed to a California misdemeanor or a felony.

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?
  • 2.1. No U-turn
  • 2.2. No business district
  • 2.3. Necessity
• 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?
  • 6.1. Yielding when turning left and making a U-turn – CVC 21801
  • 6.2. Disobeying a sign, signal, or traffic control device – CVC 38300
  • 6.3. Lane weaving – CVC 21658

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:

1. is at an intersection that does not prohibit one, or
2. 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:

1. an area where at least 50 percent of the property bordering the street is occupied by businesses, and
2. 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:

1. turning left across traffic, and then
2. 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:

1. the defendant did not make a U-turn.
2. the defendant was not in a business district.
3. 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:

1. he/she did make a U-turn, but
2. it was not made in a business district.

2.3. Necessity

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:

1. a ticket (usually in an amount of $238), and
2. 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:

• up to six months in county jail (as opposed to state prison), and/or
• a fine of up to $1,000.⁷

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.

Proving negligence can sometimes be difficult. But, in California, a driver is considered “negligent per se” if he/she violates a statute. This means a driver would be negligent per se for:

1. causing an accident, and
2. 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:

1. yielding when turning left and making a U-turn – CVC 21801,
2. disobeying a sign, signal, or traffic control device – CVC 38300, and
3. 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:

• sign,
• 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.

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