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

Vehicle Code § 22102 CVC is the California statute that makes it a traffic infraction 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.

The language of the statute reads as follows:

22102. 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 in accordance with Section 21651. 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, when more than one lane in the direction of travel is present.

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.

You can raise a legal defense to challenge an illegal U-turn ticket. Common defenses include showing that you:

• did not make a U-turn,
• were 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 your DMV driving record.

The DMV can do the following if you receive a certain amount of points within a 1-, 2- or 3-year period:

• declare you a negligent operator, and
• suspend, or even revoke, your driving privileges.

Our California auto accident 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. You did not make a U-turn
  • 2.2. You were not in a business district
  • 2.3. You acted out of 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 to make a U-turn in a business district.¹

There are two exceptions to this general rule. You can make a U-turn if you:

1. are at an intersection that does not prohibit one, or
2. are on a divided highway and are 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. you can access them from the road.³

Note that if you make a U-turn, you must make the turn as close as possible to the left-hand edge of the lane moving in your direction.⁴

Note also that this law does not prohibit you 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. you did not make a U-turn.
2. you were not in a business district.
3. you acted out of necessity.

2.1. You did not make a U-turn

This statute only applies to U-turns. This means it is always a defense to show that you made some movement other than a U-turn. Perhaps, for example, you made a right turn or a left turn.

2.2. You were not in a 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 to say that:

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

2.3. You acted out of a necessity

Under a necessity defense, you try to avoid guilt by showing that you had a sufficiently good reason to commit the crime.

In the context of this statute, you can attempt to show that you committed the crime because there was no other choice. Perhaps, for example, you had to make an illegal U-turn because of an emergency.

3. What are the penalties?

There are two penalties for violating 22102 CVC. These are:

1. a ticket (usually in an amount of $238), and
2. one point placed on your DMV driving record.

The DMV can do the following if you accrue enough points within a 1-, 2- or 3-year period:

• declare you a negligent operator, and
• suspend, or even revoke, your driving privileges.

Note too that a traffic ticket can result in an increase in your insurance rates.

4. What if I simply ignore the ticket?

Ignoring 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 you are issued a traffic ticket in California, you have to sign a written promise to appear in court.

If you willfully fail to appear as promised, you violate 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?

If you violate these laws, you may cause an accident with another motorist (such as in a head-on collision or a T-bone accident). If the motorist is injured and later files a personal injury lawsuit against you, you 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, you are considered “negligent per se” if you violate a statute. This means you 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 turning left or completing a U-turn to the left and facing oncoming traffic.

The law says that you must yield the right-of-way to approaching traffic up until you complete 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 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 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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