State Law Roundup: Including a bicyclist in the Pennsylvania Supreme Court Case

For many states, legislatures call it a year in the spring and their legal changes go into effect in the summer. Unlike my last legal roundup, which focused on active cases, this legal roundup shows recent developments that are now the law of the land in their respective states. This summer sees a wide range of new laws and legal developments.

The League of American Bicyclists does not typically participate in lawsuits as part of our advocacy. One notable exception was joining a lawsuit against the Florida Department of Transportation about its complete streets law about 17 years ago. And now, another is joining Bike PGH to submit an Amicus Brief to the Pennsylvania Supreme Court in support of the bicyclist Brendan Linton. 

In that case, Mr. Linton was pulled over for impeding traffic while riding in a travel lane. The district and appellate court upheld his ticket and articulated that he was required to leave the travel lane to let impeded vehicles pass. The Pennsylvania Supreme Court reviewed to decide whether the statute compelled Mr. Linton to leave the travel lane. 

The Pennsylvania Supreme Court decided that Pennsylvania law did not create an affirmative duty that compelled Mr. Linton to leave the travel lane to allow faster vehicles to pass. Instead, the Supreme Court said whether a bicyclist can be ticketed for not leaving the travel lane to allow faster vehicles to pass requires a consideration of the totality of the circumstances to account for Mr. Linton’s right to ride safely in the travel lane. The case was set back to district court for consideration under this newly articulated standard. 

Why this matters: Many states have laws against impeding traffic and require slow moving vehicles to move out of the way to let other vehicles pass. In most circumstances, bicyclists are slower moving than vehicles, but it is rare for state laws to directly address how courts should resolve the right of bicyclists to ride safely and laws against impeding. In this case, the Pennsylvania Supreme Court said that the safety of the bicyclist matters and impeding traffic alone does not lead to a ticketable offense if the circumstances justify the bicyclist remaining in the lane. 

In addition to litigation, July in many states means that laws passed during the last legislative session become effective. According to the National Conference of State Legislatures, more than 300 bills related to pedestrian and bicyclist safety were introduced in 37 states in 2025. Out of those more than 300 bills, only 21 were either enacted or adopted. Some of the highlights include:

• Utah House Bill 290 updates Utah law to clarify the conditions under which a motor vehicle can be operated in a bike lane.
• Texas Senate Bill 2039 updates Texas law to create a term “sidewalk user” that includes bicyclists and defines rights related to crossing at crosswalks and stop signs for “sidewalk users.”
• Tennessee Senate Bill 1420 requires that questions related to bicyclist hand signals are administered as part of driver licensing.
• New Mexico Senate Bill 73 adopts a version of the “Idaho Stop” to allow bicyclists to treat stop signs as yield signs and red lights as stop signs.
• Nevada Senate Bill 320 and Hawaii Senate Bill 1195 adopted a “daylighting” requirement that prohibits parking within 20 feet of a marked or unmarked crosswalk to improve visibility at intersections.
• Montana Senate Bill 471 updates Montana law to define pedestrian rights when specified types of pedestrian-actuated lighting are activated at a road crossing.
• Maryland House Bill 375, “Jay’s Law,” updates Maryland law so that riding a bicycle on a sidewalk is legal unless prohibited by a local ordinance, reversing the previous rule.

Explore the League’s Bike Law University to learn more about state laws » 

While not directly bicycle-related, Families for Safe Streets had success with their #StopSuperSpeeders campaign to introduce and pass legislation allowing or requiring speed-limiting devices for drivers with certain speeding-related offenses. The District of Columbia was the first jurisdiction to pass such a law in 2024 and 2025 saw legislation introduced in seven states. Two states successfully passed #StopSuperSpeeders legislation:

Virginia House Bill 2096 and Washington House Bill 1596 authorized the installation of intelligent speed assistance devices in the motor vehicles of drivers who violate certain speeding-related laws or have multiple speeding-related violations.

Several states still have open legislative sessions. We’ll continue to watch this space and watch out for how bicyclists might be impacted.