Secor v. Kohl

In Secor v. Kohl (67 AD2d 358 [1979]), the Appellate Court, upholding the decision of the Trial Court, concluded that it would be impossible for a bicyclist to give a continuous hand signal for 100 feet before making a turn because taking the hand off the handlebars would cause instability of the bike and create a danger to the bicyclist. Accordingly, the Court concluded that Vehicle and Traffic Law Section 1163(b) of the Vehicle and Traffic Law, which requires a driver to signal a turn for a full 100 feet before turning, did not apply to a cyclist.