Can municipal ordinances override state bicycle traffic laws? Hansen v. Eyre Explained

In Hansen v. Eyre, the Utah Court of Appeals addressed whether a Salt Lake City ordinance could permit bicyclists to ride against traffic flow in designated bicycle lanes when state law requires vehicles to operate on the right half of roadways.

Background and Facts
Tyler Hansen was riding his bicycle eastbound against traffic in a marked bicycle lane when Amanda Eyre, attempting to turn right, collided with him. Hansen filed suit and moved for partial summary judgment, arguing that Salt Lake City Ordinance 12.80.070 gave him the legal right to ride against traffic in designated bicycle lanes. The ordinance stated it was unlawful for bicyclists to ride on the left-hand side of any street “except when they are within a marked bicycle lane.”

Key Legal Issues
The case turned on whether the municipal ordinance conflicted with state law and whether Hansen had statutory authority to ride against traffic. The court had to interpret Utah’s Traffic Control Act, specifically sections 41-6-53 (requiring vehicles to operate on the right half of roadways) and 41-6-87 (governing bicycle operation), to determine if any exceptions applied.

Court’s Analysis and Holding
The court applied established statutory interpretation principles, reading the Traffic Control Act as a whole and harmonizing its provisions. The court determined that bicycles are “vehicles” under section 41-6-1(55) and that bicycle paths within roadways are subject to the Traffic Control Act’s limitations. Section 41-6-53 requires all vehicles to operate “upon the right half of the roadway,” and no clear exception exists for bicycle lanes. The court found that section 41-6-87(3), requiring use of bicycle paths “adjacent to” roadways, applies only to paths separate from the roadway, not paths within it. Under the principle that specific provisions govern general ones, section 41-6-53’s specific directional requirement controls over section 41-6-87’s general bicycle regulations.

Practice Implications
This decision reinforces that municipal ordinances cannot conflict with state statutory schemes. When analyzing potential conflicts between local and state law, practitioners should examine whether the state legislature has comprehensively regulated the subject matter and whether specific statutory provisions govern over general ones. The court’s in pari materia analysis demonstrates the importance of reading related statutes together to determine legislative intent.