James Heselden, the owner of the company that makes the Segway personal transporter, died recently after driving his Segway off a cliff. It appears to have been a tragic accident, and the accounts I’ve read suggest that Heselden was an interesting person and a remarkable philanthropist. Thinking about Segways, though, reminded me that I’ve been meaning to do a post about what counts as a “vehicle” for purposes of our motor vehicle laws. G.S. 20-4.01 defines a variety of specific types of vehicles, including all-terrain vehicles, commercial motor vehicles, and recreational vehicles, among others. But most questions concern whether a specific conveyance is a “vehicle” or a “motor vehicle.” The latter term is defined in G.S. 20-4.01(23) simply to mean “[e]very vehicle which is self-propelled” except mopeds, so litigation tends to focus on the definition of a “vehicle.” Under G.S. 20-4.01(49), a vehicle is “[e]very device in, upon, or by which any person or property is or may be transported or drawn upon a highway,” including bicycles but not other human-powered devices, and generally not including mobility devices for the disabled. Overall, then, a motor vehicle is any powered device that allows the movement of people or property upon a highway. That sounds quite broad, and our courts have generally read it accordingly. Here are a few cases on point: State v. Crow, 175 N.C. App. 119 (2005) (stand-up scooter with electric motor a motor vehicle sufficient to support DWI conviction) State v. Dellinger, 73 N.C. App. 685 (1985) (horse a [...]
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