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Name: People v. Gray
Case #: S202483
Court: CA Supreme Court
District CalSup
Opinion Date: 03/13/2014

Under Vehicle Code section 21455.5, subdivision (b), when a city installs a device at an intersection that photographs red light violators, it must first provide a public announcement; this requirement applies to each separate installation. Vehicle Code section 21453, subdivision (a) allows a city to install automated traffic enforcement systems at intersections that will photograph a driver who fails to comply with the traffic signal. Section 21455.5, subdivision (b) requires the city to make a public announcement of the system at least 30 days prior to the commencement of the enforcement program, and to only issue warnings to violators for the first 30 days. In June 2006, Culver City installed a system at an intersection without complying with the public announcement or 30-day warning period. Two years later, the system photographed appellant as he drove through a red light, and a citation was issued. Applying rules of statutory construction, the court agreed with appellant’s argument that the word “system” in section 21455.5 refers to the camera at a particular intersection rather than the entire city-wide red light camera enforcement program. Thus, for each new camera installed at an intersection, there must be compliance with the public announcement and 30-day warning period. However, these requirements are for the benefit of those violators within the initial 30 days after the system is activated and are not a jurisdictional prerequisite to enforcement of the red light traffic law. Thus, appellant’s conviction for a red light violation two years after the system was installed was valid.