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Lights Cases Summarized By Personal Injury Attorney

This page within Virginia Tort Case Law is a compilation of cases reported by the Virginia Supreme Court and summarized by Brien Roche dealing with the topic of Lights. For more information about traffic collisions see the pages on Wikipedia.


See Va. Code §§ 46.2-1010 through 46.2-1037.


1991 Hack v. Nester, 241 Va. 499, 404 S.E.2d 42.

Absence of one headlight sufficient to create jury issue of negligent entrustment.

1988 Karim v. Grover, 235 Va. 550, 369 S.E.2d 185.

Plaintiff on bike, which lacked a front headlight. Although this may be negligence, issue of proximate cause was for jury.

1977 King v. Commonwealth, 217 Va. 601, 231 S.E.2d 312.

Failure to turn on white headlights, instead of amber parking lights, while driving in open country after 11:00 p.m. was no more than ordinary negligence.

1973 Habers v. Madigan, 213 Va. 485, 193 S.E.2d 653.

Motor vehicle guest case. Taillight on tractor extremely dirty and poorly visible. Question of gross negligence involved. Evidence of experiment, re: visibility of taillight discussed. Evidence of excessive speed and that dome light inside car was on after impact created jury issue on gross negligence.

1970 Yates v. Potts, 210 Va. 636, 172 S.E.2d 784.

Absence of brake lights and turn signal presented jury issue in regard to rearender.

1970 Biggs v. Martin, 210 Va. 630, 172 S.E.2d 767.

Rear-ender. Absence of taillight presented jury issue as to liability.

1969 Hagan v. Hicks, 209 Va. 499, 165 S.E.2d 421.

Decedent ran into delivery truck that was without proper lights at night, stopped on highway, and loaded with heavy logs that extended six or seven feet past truck. Verdict for plaintiff.

1968 Johnson v. Wilmoth, 209 Va. 82, 161 S.E.2d 682.

Defendant blinded by headlights of oncoming vehicle, struck plaintiff either on shoulder or on roadway. Question of negligence and contributory negligence for jury. Virginia does not follow rule of strict liability for temporary impairment of vision by glaring lights which requires motorist to stop or proceed at his peril.

1968 National Union Fire Ins. v. Bruce, 208 Va. 595, 159 S.E.2d 815.

Defendant was allegedly operating his vehicle without headlights. May constitute gross negligence.

1967 Dickenson v. Tabb, 208 Va. 184, 156 S.E.2d 795.

Defendant was blinded by lights ahead which so happened to be two-vehicle wreckage. Defendant did not slow down until 10 feet away. Motorist temporarily blinded by lights must exercise caution commensurate with situation.

1966 Sexton v. Stroman, 207 Va. 33, 147 S.E.2d 758.

Plaintiff stopped suddenly to avoid striking vehicle in her lane when defendant struck her from rear. Conflict as to whether plaintiff’s brake lights were working. Verdict for defendant supported by evidence; error to set aside.

1966 Hall v. Hockaday, 206 Va. 792, 146 S.E.2d 215.

Fact that vehicle involved in accident was 1952 vehicle does not mean that later laws are not applicable to it as far as lights.

1963 Giannone v. Johnson, 204 Va. 493, 132 S.E.2d 445.

Plaintiff claims that his vision was obstructed by headlights shining across street in front of him. It is normally jury question as to whether plaintiff has used ordinary care where he claims that blinding lights caused him to collide.

1963 Carter v. Nelms, 204 Va. 338, 131 S.E.2d 401.

Defendant operated automobile without headlights. Factual question for jury was whether headlights were required since it was allegedly snowing and near sunset.

1962 Allen v. Brooks, 203 Va. 357, 124 S.E.2d 18.

Virginia Code § 46.1-268 regarding lights on vehicle applies to vehicles parked on roadway. Localities are authorized to provide that lights need not be displayed if vehicle is parked in accordance with ordinance.

1959 Smith v. New Dixie Lines, 201 Va. 466, 111 S.E.2d 434.

Tractor-trailer approaching vehicle plaintiff was riding in had high beams on that blinded plaintiff. This was negligence per se.

1959 Jones v. Aluminum Window & Door Corp., 201 Va. 283, 110 S.E.2d 531.

Instruction incorrectly stated requirement as to auto lights. Instruction stated it was duty of defendant to have lights sufficient so that he could discern bicyclist on right shoulder.

1957 Simmons v. Craig, 199 Va. 338, 99 S.E.2d 641.

Defendant’s failure to have his headlights on was cause of accident.

1956 Shelton v. Detamore, 198 Va. 220, 93 S.E.2d 314.

Driving without headlights when natural light is insufficient to enable operator of vehicle to discern object at distance of 300 feet is negligence per se.

1954 Hobbs v. Thorns, 195 Va. 639, 79 S.E.2d 854.

Intersection collision at dusk; defendant driving with only parking lights on. Jury found for plaintiff.

1951 Reese v. Snelson, 192 Va. 479, 65 S.E.2d 547.

Instruction on required intensity of headlights, where there is no evidence of defendant’s headlights not having met this requirement is unnecessary.

1951 Leo Butler Co. v. Wilbun, 192 Va. 263, 64 S.E.2d 738.

Witness testified that he looked in particular direction for purpose of seeing if way was clear and saw no headlights approaching; this is positive testimony that defendant was operating his car at night without lights.

1949 Crist v. Fitzgerald, 189 Va. 109, 52 S.E.2d 145.

Defendant failed to have lights on rear of vehicle at night. Negligence per se.

1948 Marks v. Ore, 187 Va. 146, 45 S.E.2d 894.

Defendant’s vehicles were parked on roadway without lights or flares. Verdict for plaintiff.

1948 Millard v. Cohen, 187 Va. 44, 46 S.E.2d 2.

In absence of evidence to contrary, conclusive presumption is that lights were burning. Failure to see unlit vehicle stopped in lane of traffic is not gross negligence.

1946 Highway Express Lines v. Fleming, 185 Va. 666, 40 S.E.2d 294.

Horse-drawn vehicle without lights at night rear-ended. Plaintiff sued striking vehicle and recovered.

1946 Nelson v. Dayton, 184 Va. 754, 36 S.E.2d 535.

One who drives faster than he should in face of blinding headlights is required to exercise increased diligence to avoid injury.

1945 Godwin v. Camp Mfg. Co., 183 Va. 528, 32 S.E.2d 674.

Railroad cars were blocking crossing. Cars were unlit. Vehicle struck cars. Jury issue.

1943 Reid v. Boward, 181 Va. 718, 26 S.E.2d 27.

Tractor-trailer was alleged not to have proper lights.

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Lights Cases Summarized By Personal Injury Attorney

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