Starting a vehicle from a parked, stopped, or standing position when it is not reasonably safe to do so, creating a hazard for approaching traffic.
This guide is for general educational purposes only and does not constitute legal advice. TicketClear is a self-help document preparation service — we are not attorneys and do not represent clients. Review all prepared documents carefully before submitting. Fine amounts are estimates and vary by county and surcharge schedule.
CVC 22106 applies when you pull out from a parked position or back up on a roadway without ensuring it's safe to do so. This violation is commonly cited when a driver enters traffic from a parking spot and causes another vehicle to brake or swerve, or when backing creates a hazard.
A CVC 22106 ticket typically costs $238 to $350 after court fees and adds 1 point to your DMV record. This point stays on your record for 3 years and can increase your auto insurance premiums by 15-25% annually.
One point for a moving violation typically increases insurance premiums by 15-25% for about 3 years. Completing traffic school prevents the point from appearing on your public driving record, which keeps insurers from seeing it.
No person shall start a vehicle stopped, standing, or parked on a highway, nor shall any person back a vehicle on a highway until such movement can be made with reasonable safety.
Driver pulls out of a parallel parking spot on a busy street and a car behind has to slow down slightly
Officer cites for 22106, but defense argues the other car had plenty of time to adjust and no actual hazard existed
Driver backs out of a driveway onto the street without looking and nearly hits a passing cyclist
Clear violation because the movement created an immediate hazard for the cyclist
Driver waits for traffic to clear, then pulls out from street parking, but an officer across the intersection believes it was unsafe
Defensible if driver can show they checked mirrors and traffic conditions were actually clear from their position
These are the defense arguments that appear most often in successful Trial by Written Declarations for this violation.
Backing movement was safe
CVC 22106 prohibits starting or backing a vehicle when it is not safe. If you checked for clearance, moved slowly, and no vehicle or pedestrian was endangered, the movement may have been safe.
Officer's position
Challenge whether the officer observed the full maneuver or arrived after the movement was complete.
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No, but the prosecution must show the movement created some hazard. If another car merely noticed you but didn't have to take evasive action, you have grounds to argue no unsafe condition existed.
Yes. CVC 22106 doesn't require a collision—just that you started moving when it wasn't reasonably safe. Officers often cite this when they observe a close call or near-miss situation.
The law applies to any starting movement onto a highway, which includes most public roads. Whether from a driveway, parking spot, or curb, the same reasonable safety standard applies.
Dashcam footage is the strongest evidence. Without it, you can describe your routine safety check in your declaration and note that conditions appeared safe from your vantage point when you began moving.
Yes. CVC 22106 specifically applies when starting from a stopped position, while unsafe lane change (CVC 21658) applies when you're already in traffic flow. The elements and defenses differ between these violations.
Traffic School Option
Most drivers are eligible for traffic school to mask this point if they haven't attended in the past 18 months and have a valid non-commercial license. Check eligibility on your ticket or courtesy notice.
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This guide is for general educational purposes only and does not constitute legal advice. TicketClear is a self-help document preparation service — we are not attorneys and do not represent clients. Review all prepared documents carefully before submitting. Fine amounts are estimates and vary by county and surcharge schedule.
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