Changing Lanes on a Highway: Is a Turn Signal Required by Law?

Written by Gregory Monte.

I have written several posts about how most traffic ticket websites are worthless.

• Most Traffic Ticket Websites Are Worthless.

• Yet Another Worthless Traffic Ticket Website

Well I just found another one – a law firm – that provides incorrect information about the topic of signaling when changing lanes. In a post entitled Do I Have to Signal to Change Lanes?, the author categorizes states based on their lane signaling laws:

• Required to Signal
• Not Required
• It Depends …

The only problem is that the information provided is not correct for some of the states.  While I didn’t get the chance to check out each and every motor vehicle code, I did review New York, New Jersey and Pennsylvania’s.

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A Signal is Required – New York, New Jersey & Pennsylvania

The article cited above indicates that no signal is required to change lanes in New York, New Jersey and Pennsylvania (among many others).  But if you go directly to these state’s Motor Vehicle Codes, you find that this is completely wrong.

Starting with New York’s VAT Code Section 1163, you read the following:

“No person shall … otherwise turn a vehicle from a direct course or move right or left upon a roadway … without giving an appropriate signal …”

You will find the exact same language in New Jersey’s Code Section 39: 4-126:

“No person shall … otherwise turn a vehicle from a direct course or move right or left upon a roadway … without giving an appropriate signal …”

Pennsylvania’s Title 75, Section 3334 uses different language but the message is equally clear:

“Upon a roadway no person shall … move from one traffic lane to another … without giving an appropriate signal …”

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The Traffic Ticket Defense Blog Difference

If the writers on an actual law firm website don’t take the time to do a simple check of the statutes before publishing a report, how can you even think to trust any of the other “non-lawyer” sites out there that claim to provide traffic advice?

Well, unlike so many other traffic ticket help websites, I don’t just re-post/rehash other blog post commentary.  Instead, I do my own research using the original source documents.  These original documents can be actual motor vehicle codes (like I quoted today), or it can be actual case law from a particular state. 

In fact, tomorrow I intend to revisit the lane-change topic to discuss how long a motorist has to signal before he can change lanes.  In that post I will quote both statute and case law to prove my point.

If you want to get an idea of how I specifically apply this statute/case law method to beating a stop sign ticket, check out my two free PDFs:

• The Pennsylvania Stop Sign Ticket Defense Strategy in a Nutshell
• My Son’s Opening Trial Statement at the Court of Common Pleas

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New York Case Law – Two Views

You can kind of understand the confusion about signal requirements if you read the following two New York cases:

Signal Not Always Required – People v. Rice

In People v. Rice, 11 Misc. 3d 539 – NY: Supreme Court 2006 the court held that “the Vehicle and Traffic Law does not require the operator of a motor vehicle to signal every lane change.”

Signal Always Required – People v. James

In People v. James, 17 Misc. 3d 623 – NY: City Court, Criminal Court 2007 the court found “… that the plain language of Vehicle and Traffic Law § 1163 mandates that a driver signal prior to a lane change in all circumstances.”