In People v. Spriggs, decided on February 27, 2014, the California Court of Appeal held that a driver using a map application did not violate Vehicle Code section 23123(a), which prohibits a person from driving "while using a wireless telephone unless that telephone is specifically designed and configured to allow hands-free listening and talking, and is used in that manner while driving." The Court, based on a review of the legislative history of the provision, held the statute only prohibited use of a wireless phone to engage in conversation unless the phone was used in a hands-free manner. The People asserted the legislation was intended to prohibit all uses of a hands-free phone except where it is used in a hands-free manner. The Court noted that would lead to absurd results and that the other statutory provisions prohibit use of a cell phone to write or send text-based communications and the use of a cell phone in any manner by a driver under 18 years of age.
April 10, 2014