California, United States of America
The following excerpt is from People v. Hendrickson, C076597 (Cal. App. 2016):
The motion asserted that the traffic stop was unlawful because section 24400, on which the deputy relied to make the stop, prohibits driving with a nonoperable headlight only on a public road or highway.2 It does not apply on private property. (See People v. Lopez (1987) 197 Cal.App.3d 93, 98-101 (Lopez) [unlawful to detain a person for possessing open beer can in vehicle while parked in a parking lot because Vehicle Code provision barring open beer can in vehicle applied only "upon a highway"].) Thus, even assuming defendant was driving in the parking lot with a nonoperable headlight, she had not committed a traffic violation.
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