Beale v. Dept. of Motor Vehicles

CourtCalifornia Court of Appeal
DecidedMay 21, 2026
DocketH052612
StatusPublished

This text of Beale v. Dept. of Motor Vehicles (Beale v. Dept. of Motor Vehicles) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beale v. Dept. of Motor Vehicles, (Cal. Ct. App. 2026).

Opinion

Filed 5/21/26 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

DAVID KEITH BEALE, H052612 (Santa Clara County Plaintiff and Appellant, Super. Ct. No. 23CV418048)

v.

DEPARTMENT OF MOTOR VEHICLES,

Defendant and Respondent.

This is an appeal from a denial of a petition for writ of mandate against the California Department of Motor Vehicles (DMV) after it suspended appellant David Keith Beale’s driver’s license for riding an electric bicycle under the influence of alcohol and refusing to submit to a blood alcohol test. Beale argues that an electric bicycle is not a “motor vehicle” under Vehicle Code section 13353 and that there was therefore no basis for suspending his license. We agree with Beale that the statutory scheme does not authorize the suspension of an electric bicycle rider’s driver’s license, even if the rider refuses a police officer’s request to take a chemical test. On this basis, we reverse. I. BACKGROUND A. The Incident On August 16, 2022, at approximately 7:30 p.m., San Jose Police Officer Nickolas Corini responded to a report of a man on a “motorized bicycle” who had hit a curb and injured his head. Officer Corini located the man on his “motorized/electric bicycle” at the scene, and the man identified himself as Beale. Corini smelled alcohol on Beale’s breath and saw that he had bloodshot eyes. Corini proceeded to ask Beale a series of “intoxication questions.” After initially agreeing to perform field sobriety exercises, Beale then refused to do several of them because of balance issues. Beale also refused to consent to a preliminary alcohol screening test. Corini determined that Beale was operating a motor vehicle under the influence of an alcoholic beverage in violation of Vehicle Code section 23152, subdivision (a), and placed him in handcuffs in the back of the patrol vehicle. 1 Corini asked if Beale would be willing to “provide a blood or breath sample per DMV’s Implied Consent,” and Beale refused. At 12:20 a.m. on August 17, Officer Corini procured a blood sample from Beale pursuant to a judicial warrant. The test showed a blood alcohol level of 0.113 percent. Beale received a suspension/revocation order and temporary driver’s license with a notification that he had 10 days to request a hearing to show that the suspension of his license was not justified. B. The APS Hearings On December 9, 2022, the DMV held an initial “administrative per se” (APS) hearing under section 13353, at which the hearing officer and Beale’s attorney discussed whether Beale’s bicycle was an “electric bicycle” or a “motorized bicycle.” The hearing officer ultimately continued the hearing so that Beale’s counsel could obtain further information to show which Vehicle Code sections should apply, and for the parties to determine whether “the hearing [should] even proceed at that point” or whether the bicycle might “be exempt.” The DMV held the continued APS hearing on May 18, 2023 before a different hearing officer. At the hearing, Beale’s attorney argued that Beale had an electric bicycle, which is not a motor vehicle and therefore not subject to the Vehicle Code provisions for the suspension of a driver’s license. Beale’s attorney submitted a

1 Subsequent undesignated statutory references are to the Vehicle Code. Section 23152, subdivision (a) states, “It is unlawful for a person who is under the influence of any alcoholic beverage to drive a vehicle.”

2 declaration from the deputy district attorney in the corresponding criminal case, in which the prosecutor sought to amend the charge against Beale from a violation of section 23152 to a violation of section 21200.5 (riding a bicycle while under the influence). The prosecutor’s declaration asserted that an “electric bike” does not meet the statutory definition of a “motor vehicle” under section 23152. 2 Beale presented an expert witness, Douglas Schwartz, who stated that he runs “probably the largest electric bike store in Northern California.” Schwartz testified that an electric bicycle is different from a “moped motorized bicycle” because an electric bicycle does not require any type of licensing, has an upper speed limit of 28 miles an hour, and is required to have pedals. He also testified that electric bicycles are governed by the Consumer Product Safety Commission rather than the Department of Transportation, in contrast to mopeds. Schwartz looked at photographs of Beale’s bicycle and identified it as a “Class 2” electric bicycle. During the hearing, the hearing officer asked several clarifying questions of Schwartz regarding the difference between an electric bicycle and a moped, as well as the difference between an electric bicycle and a regular bicycle. The hearing officer also asked about the location of the battery and the lack of any requirement for a license or registration to ride an electric bicycle. On May 23, 2023, the DMV issued its decision. The hearing officer found that “Officer Corini had reasonable cause to believe that [Beale] was driving a motor vehicle under the influence of alcohol.” The hearing officer further concluded that Beale was “lawfully arrested for a violation of Vehicle Code Section 23152, 23153, or 23140.” The hearing officer made the additional determinations that “[a]n electric bicycle that can move itself is a bicycle, but it is also a motor vehicle,” and that “a bicycle rider has

2 Notwithstanding this concession, section 23152 uses the term “vehicle” rather than “motor vehicle,” as quoted in the previous footnote.

3 essentially the same rights and responsibilities as the driver of any vehicle,” citing sections 21200, subdivision (a)(1), 21200.5, and 23612. Based on the totality of the evidence, the hearing officer concluded, “[T]he department’s administrative action is deemed warranted.” The hearing officer upheld the suspension of Beale’s driver’s license for the period of June 2, 2023 through June 1, 2024. 3 C. The Trial Court Proceedings On June 26, 2023, Beale filed a petition for writ of mandate in the Santa Clara County Superior Court. He argued that he rode a bicycle, not a motor vehicle, and was therefore not lawfully arrested for a violation of section 23152 or subject to an APS suspension of his driver’s license. On November 3, 2023, Beale filed a supplemental memorandum of points and authorities in which he argued that the APS hearing also violated his due process rights because it combined the advocacy and adjudicatory roles of a prosecutor and decision maker into a single DMV employee. The DMV submitted a written opposition to the petition, arguing that Beale had waived any due process challenge because he never raised the issue during the APS hearings, that the hearing officer acted as a factfinder and not as an advocate, and that Beale did not demonstrate any prejudice in any event. As for the license suspension, the DMV argued that whether an electric bicycle is a motor vehicle is irrelevant because “bicyclists are subject to the same rules as drivers of vehicles.” The DMV further argued that even if it were necessary to determine whether an electric bicycle is a motor vehicle under section 13353, the court should find that the class 2 bicycle operated by Beale was more like a

3 Although that suspension period has now passed, this case is not moot: “Unless this suspension is rescinded, [appellant] would face a more severe penalty should he be found to have failed to submit to or complete a chemical test on a subsequent occasion. (Veh. Code, § 13353.)” (Fitzpatrick v. Department of Motor Vehicles (1993) 13 Cal.App.4th 1771, 1778, fn. 3.)

4 moped than a conventional bicycle, with “motor vehicle” defined broadly to achieve section 13353’s purpose of making the roads safer by removing reckless drivers. Following additional briefs from the parties, the trial court issued its decision on August 20, 2024.

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Bluebook (online)
Beale v. Dept. of Motor Vehicles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beale-v-dept-of-motor-vehicles-calctapp-2026.