Seat Belt Law and Statutory Interpretation

A few days ago I was waiting in court for a hearing and heard a trial on a seat belt violation. In my state, it is a $25 fine, no court costs, no points, not sent to the insurance company. The guy would have been better off paying the ticket instead of missing work, but he instead fought it leaving me able to post this topic.

The officer testified that he was sitting along side the road and noticed him not wearing a seat belt. He said he could view this by observing no contrasting color between the driver’s shit and a seat belt. He also stated that he could observe a seat belt near the door frame and the body of the driver IF the driver was wearing a seat belt and would not observe it if the driver was not wearing a belt.

The defendant candidly testified that he was wearing his seat belt, however he was wearing the belt underneath his shoulder, through his armpit. The officer testified that if that was true, he would still be in violation of the law. (I wanted to object myself as a police officer cannot testify to what a law means). The judge, at the end of the hearing, ruled that he credited the defendant’s word that he did wear his seat belt under his armpit, but he was guilty as he was not wearing it properly.

Here is the law:

(a) A person may not operate a passenger vehicle on a public street or highway of this state unless the person, any passenger in the back seat under eighteen years of age, and any passenger in the front seat of the passenger vehicle is restrained by a safety belt meeting applicable federal motor vehicle safety standards. For the purposes of this section, the term “passenger vehicle” means a motor vehicle which is designed for transporting ten passengers or less, including the driver, except that the term does not include a motorcycle, a trailer, or any motor vehicle which is not required on the date of the enactment of this section under a federal motor vehicle safety standard to be equipped with a belt system. The provisions of this section apply to all passenger vehicles manufactured after January 1, 1967, and being 1968 models and newer.

The defendant argued that he was indeed restrained by a seat belt, and therefore had complied with the law. The prosecutor argued, rather poorly, I thought, that the law stated that he had to wear it according to “applicable federal motor vehicle safety standards.” I think that part of the law refers only to the seat belts themselves and not how a person wears them.

At the end of the case, I was convinced that the judge was right. Yes, the law says “restrained” but I think it is only reasonable to read that as restrained in the ordinary and customary way that seat belts restrain people. You do have to wear them correctly. Otherwise you could wrap it around your right wrist and claim that you were restrained. On the other hand, the defendant had a good argument. The legislature could have easily put that language in there, but did not. He was “restrained” by a seat belt, and was therefore in compliance. But I think the State has the better of this one.

One thing I noticed was that the State put on no evidence of the type of vehicle he was driving. They didn’t establish that the vehicle was a 1967 or newer model. I told the prosecutor this and he said that in his opinion, one could assume that the vehicle was newer than 53 years old. I disagreed. I think it was an element of the offense that the State had a burden to establish. But the prosecutor did make a good point. Let’s say that the law is the same another 50 years from now. When does the burden fall from the State to keep proving that a car is not ancient? What about 500 years?

Also, after court, I was waiting in the Wal-Mart parking lot to pick up my grocery order. I watched cars going by on a similar road to where the officer testified he pulled the defendant over. There is No Fucking Way, he could observe anything about seat belt use. All cars have tinted windows and there is simply no way he saw anything of the sort. Did he perjure himself or have better eye sight than me? Maybe, but I was astounded by that. On my way home I tried to determine if people were wearing seat belts. I could not.

So this was a nice little exercise in statutory construction for me, and while I would have found the guy guilty on his own argument, I would have held the State responsible for proving that the vehicle was a 67 model or newer. What say ye dopers? Am I too strict or too lenient? How would you have ruled? Would you be upset with the officer’s testimony if you viewed the same thing I did? Try it for yourself.

I don’t think I want to know how the officer determined the color of the driver’s shit, but from my brief googling, it seems cops doing a visual check for the seatbelt over the shoulder is a common and accurate practice.

The fact you were unable to do so doesn’t mean officers wouldn’t be able to. What time of day did the officer stop the idiot–I mean defendant? It’s apparently much easier to determine seatbelt compliance in the daytime. If your trip to WalMart was at a time or under conditions where ambient light was poorer, that would be one explanation as to why you couldn’t see whether drivers wore seatbelts. And apparently the 15-20% standard factory tint on newer cars isn’t enough to obscure cops’ vision, during daylight, at least. .

I guess your state’s legislators assumed drivers wouldn’t be hair-splitting idiots like the defendant–always a dangerous assumption. My state’s law explicitly says the seatbelt must go over the shoulder. Perhaps the WV legislation should be amended, but I wouldn’t assume the cop was lying–not when it’s a standard means of determining seatbelt compliance by cops everywhere.

Many cops will simply try to educate the driver on why wearing a shoulder harness under the arm is stupid. My guess is this guy was enough of a stubborn, argumentative jackass that the officer saw the lesson was not going to take.

If the defendant had said “My car is a 1966 model”, the State would have pulled up the car’s registration data and said “This says it’s a 1988 Honda”. Do you really think that, unprompted by the defendant calling it into question, the prosecutor should routinely include reading basic information from the car registration into the court record?

I think if the law was changed just 5 years ago, they would include it as a rule, because they knew it was a likely point to be raised, but with the limit being 1967 it’s entirely reasonable in 2020 to wait until that element of the law is invoked by the defendant to present the easily available evidence that it applies.

This law has essentially no consequences if broken. Contesting the ticket was obviously for entertainment purposes only.

The jerk probably was not wearing the seatbelt.

His consequences will arrive if he ever gets in an accident. Most insurance policies mandate seat belt use. If the damage to either property and/or person do not demonstrate the seat belt was worn, he could very well end up paying for everything.

Or his survivors will.

~VOW

Several years ago I was driving to work in the early morning in my Jeep Wrangler [dark blue], and happened to be wearing a black shirt. I was stopped for a red light, and a sheriff’s deputy to my left (who had the green), started to drive through and then starting staring at me. He then slowly veered toward me (still staring), then pulled up alongside my Jeep (so we were sitting face to face).

Then he said, “It looked like you weren’t wearing a seatbelt.” I asked why, and he said something to the effect of my shirt was black and so was the seat belt.

Then he told me to be careful wearing dark shirts with seat belts, and to have a good day, and drove off.

But it is a criminal case. The defendant has no obligation to say or do anything. If the law requires the car to be manufactured after January 1, 1967 then why is it not the duty of the state to introduce that into evidence? As you said, it is trivially easy. All the officer has to say is, “I pulled over a 2008 Honda Civic, WV license #12345A. The registration stated that it was to a Blue 2008 Honda Civic which I observed the Defendant, Mr. Smith driving.”

That “basic information” is critical for the statute to apply in the first instance and should therefore certainly be introduced by the State.

Quite possibly. But on the other hand, the kind of guy who’d go to court to contest a $25 seat belt ticket is the kind of guy who’d wear his seat belt under his arm just so he could say “He ha, Officer, I am so wearing a seatbelt.”

Was that part of the statute, that seat belts must be of sufficiently contrasting color? I think the cop is guilty of some kind of misconduct for telling you this.


That’s my post; hope you liked it!

So far as I know it’s not part statute. I just think he thought I wasn’t wearing a seat belt and was going to ticket me but then realized I was wearing one and it was because they were both the same color.

I think it was just friendly advice.

But maybe it should be part of a statute to avoid people getting pulled over for a seat belt violation when there isn’t a violation.

That was the general thought in and around the courtroom. We all had to sit around while this asshole was jerking around for his $25 no points or costs fine. Just pay the fucking thing was the consensus. I enjoyed it. If the state wants to take someone’s money for a victimless crime, then let them put out the resources, far more than $25, to take it from him.

I was also thinking, and I don’t want this to be a bomb in the thread, but what about the constitutional abortion argument. A person has the right to do what she wants with her own body. That goes so far as to allow the extermination of life or potential life growing inside the body but is weak enough to not offer protection to a person to make a choice of whether or not to wear a seatbelt? Obviously there are differences, but I think a rule of general applicability should apply.

And also with the argument that we don’t need so much police intervention in our lives. That guy was bothering nobody, yet we have an agent of the government wasting time and screwing with him over something that is only potentially harming him. And as far as the poor and minorities go (he was a white dude) these laws can be used as pretext stops for “consent” searches. So, I say good for him. If everyone fought their seat belt citation, the state would go broke prosecuting it.

too late to edit my above post. But thinking about it, it would be impossible to do contrasting colors.

In any event, why should I have to choose the correct color shirt not to be harassed by the police when I am driving to McDonalds?

^^You don’t. It was just one of those things that happened to me years ago. I was just relating a story about it.

The law does not require absolute proof, merely proof beyond a reasonable doubt. It seems to me that 52-year-old cars are rare enough, and arguments by the defense common enough, that it is beyond a reasonable doubt to assume that, if the defendant didn’t raise the age of the car as a defense, the car was not that old.

And that is a very lucid and intelligent argument. I have no real response to it other than it just seems wrong. You are, in essence, saying that the obligation is on a defendant to disprove an element of the offense instead of placing that burden on the State.

I mean, you’re right. It would be easy enough for a defendant to say, “Hey, it’s a '55 Chevy. My dad left it to me. Here’s the registration and a picture of me driving it.” But if we go with the idea that I can sit there silent and hold the State to its proof, which seems a very basic thing in our criminal justice system, I shouldn’t have to do that.

The direction from the Supreme Court is a mess regarding affirmative defenses versus elements of the offense, but it seems pretty clear that the way this law is drafted, that the age of the car is an element that should have to be proven. And again, the State could do that pretty easily.

Yeah, I kind of figured this was where you were coming from. It’s absolutely not a victimless crime.

But what about the argument that it only affects the people who choose not to wear it? This is just a myth perpetuated by people who can’t see beyond themselves. Injuries and fatalities that could have been prevented through seat belt use impact the first responders, the hospital staff, the friends and family of the victim, and every citizen that contributes tax dollars to fund medical services. I suppose someone could create a system where we leave seat belt use to individual choice and only provide emergency medical services to people who never break a safety rule, but that sounds more like the subplot of a dystopian sci-fi than a community I’d want to live in.

In addition, a seatbelt can help you avoid losing control of your vehicle in a crash and hurting or killing other drivers. Unrestrained people in a car can also hurt or kill other passengers in the car in case of a crash.

Choosing to see it, despite the evidence, as a “victimless crime” is precisely why laws had to be enacted to protect passeners and other drivers, those how have to clean up the goo that used to be the unrestrained occupant, and the taxpayers who have to pay for all the above.

The end result of that argument means that laws should be passed to prohibit all harmful private conduct: banning smoking, counting drinks, eating fatty foods, no sex without a condom, or mandating that a person have a certain BMI, because after all, we all have to pay for a person’s medical care.

And the first responders? They sign up for a job that requires them to see blood and gore.

Your proposal, if applied generally would allow the most restrictive rules ever. We would no longer be a free country.

No, it does not. You’re taking this to ridiculous extremes to make your point, which is neither rational nor realistic. Extending your line of reasoning still further, we could take it farther and say there should be no laws whatsoever because every law impinges on personal freedom and choice. You surely had to read Hobbes’ social contract theory in law school. Perhaps it’s time you refresh your memory.

And your disingenuous take on first responders doesn’t impress me. My point was not that you should feel sorry for them for having to clean up the blood, tissue, and organ and bone fragments of the idiots who refuse to wear seat belts but that doing so takes time and work that could go to others whose injuries were not the result of stubborn stupidity. I believe you realized that and chose to ignore it.

Your argument doesn’t wash here.

The standard of proof for traffic violations is preponderance of evidence in most states. Is West Virginia different?

In theory. In fighting my last ticket the judge basically said the standard of proof was the officer wrote the ticket therefore you are guilty.