Did Connecticut's 1990 vehicle-screen law allow a driver-visible monitor showing only a rear camera?

Plain-English summary

Connecticut State Police asked about a closed-circuit camera system that displayed the area behind a vehicle. The manufacturer's materials said the monitor worked only with its dedicated camera and could not receive a different video signal. The Attorney General nevertheless concluded that its display was a “television screen or other device of a similar nature” under the 1990 vehicle-equipment statute. If the monitor was visible to the driver, its use was prohibited.

The statute barred a television screen or similar device where visible to the driver or otherwise interfering with safe control, except for a video display used for instrumentation. The opinion interpreted “television” and “screen” by ordinary definitions and found that the dedicated-camera arrangement still received a signal and displayed images. It cited the earlier amendment allowing instrumentation displays as support for keeping that narrow exception distinct from the rear-camera system.

A footnote expressly said the opinion did not address whether such equipment was prohibited in law-enforcement vehicles. The opinion also did not give a general approval for monitors outside the driver's view; the statute separately mentioned interference with safe vehicle operation.

Currency note

This opinion was issued in 1990. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Historical summary

For vehicle owners and equipment suppliers: The opinion classified the described dedicated rear-camera display as a screen covered by the statute, despite the monitor's inability to receive other video sources. A driver-visible installation was prohibited under the law analyzed.

For police fleets: The opinion expressly reserved whether law-enforcement vehicles were subject to the same rule. It gave no answer for that vehicle category.

Common questions

Did a rear camera stop its monitor from counting as a television screen?

No. The Attorney General said the monitor received a signal and displayed images even though it was paired only with its own camera.

Could the monitor be visible to the driver?

Not under the 1990 rule the opinion applied. It concluded that visibility to the driver made use of the described system prohibited.

Did the instrumentation-display exception cover this rear-camera system?

The opinion treated the exception as permission for instrumentation displays and concluded that the described camera monitor remained a prohibited screen if visible to the driver.

Did the opinion decide the rule for a police vehicle?

No. Its footnote said that question had not been requested and was outside the opinion.

Background and statutory framework

The request described a “Car Vision” unit with a TV camera, monitor, and controls used to observe the rear of a vehicle. The manufacturer said the camera and monitor functioned together and could not be modified for another video source. The Attorney General read the statute's undefined screen terms according to common usage and treated the unit as covered because the monitor displayed images from a received signal.

The statute permitted a “video display unit utilized for instrumentation purposes” while restricting other driver-visible screens and devices that interfered with safe operation. The opinion relied on testimony about the instrumentation amendment, which distinguished dashboard information displays from televisions viewed by drivers. It did not analyze any later vehicle technology or changes to the statute.

Citations and references

The opinion discusses Conn. Gen. Stat. section 14-105, the ordinary-language rule in section 1-1(a), and P.A. 84-215. It cites Ziperstein v. Tax Commissioner, 178 Conn. 493, 500, 423 A.2d 129 (1979), and Johnson v. Manson, 196 Conn. 309, 316-317, 493 A.2d 846 (1985). The official HTML renders the section symbol as “e” in several citations; the original-text section preserves that rendering.

Source

• Landing page: https://portal.ct.gov/AG/Opinions
• Opinion page: https://portal.ct.gov/ag/opinions/1990-formal-opinions/major-john-watson-connecticut-state-police-1990008-formal-opinion-attorney-general-of-connecticut

Original opinion text

Major John Watson, Connecticut State Police, 1990-008 Formal Opinion, Attorney General of Connecticut

Attorney General's Opinion

Attorney General, Richard Blumenthal

February 27, 1990

Major John Watson

Executive Officer

Connecticut State Police

100 Washington Street

Hartford, CT 06106

Dear Major Watson:

In his letter to us, Lt. Col. John A. Mulligan requested our advice concerning the use of certain closed circuit video monitoring equipment to monitor the area to the rear of certain motor vehicles. His specific question to us is "whether installation and use of such equipment violates Section 14-105 of the General Statutes or any other provision of our law." For reasons explained below, our opinion is that the use of such equipment is prohibited by Conn. Gen. Stat. e14-105 if the monitor is visible to the driver.1

According to the enclosures which accompanied Lt. Col. Mulligan's letter, the equipment to which he refers is a closed circuit monitor system called "Car Vision," which "enables the user to observe and confirm situations at the vehicle's rear. Each set comprises (sic) a TV camera, monitor, and self-contained control and power units." The manufacturer of the system claims that "[t]he Car Vision camera and monitor, unlike a conventional TV camera, do not have independent functions. The camera and monitor are designed to functions (sic) as a composite body." Thus, the monitor cannot be modified to receive a video signal from a source other than the unit's dedicated video camera.

The statute which is relevant to this inquiry, e14-105, provides as follows:

No television screen or other device of a similar nature, except a video display unit utilized for instrumentation purposes, shall be installed or used in this state in any position or location in a motor vehicle where it may be visible to the driver or where it may in any other manner interfere with the safe operation and control of the vehicle. Violation of any provision of this section shall be an infraction.

The statute contains no definition of the terms "television" or "television screen." It is well-established that "[i]n the construction of statutes, words and phrases shall be construed according to the commonly approved usage of the language; and technical words and phrases, and such as have acquired a peculiar and appropriate meaning in the law, shall be construed and understood accordingly." Conn. Gen. Stat. e1-1(a). Where a statute does not define a term, it is appropriate to look to the common understanding expressed in the law and in dictionaries. Ziperstein v. Tax Commissioner, 178 Conn. 493, 500, 423 A.2d 129 (1979), Johnson v. Manson, 196 Conn. 309, 316-317, 493 A.2d 846 (1985). Webster, Third New International Dictionary, defines the word "television," in part, as "the transmission and reproduction of transient images of fixed or moving objects; specif: an electronic system of transmitting such images together with sound over a wire or through space by apparatus that converts light and sound into electrical waves and reconverts them into visible light rays and audible sound." The word "screen" is defined, in part, as "the surface upon which an image or pattern is produced in a television or radar receiver or in a similar apparatus."

In accordance with these definitions, our opinion is that the video monitoring system referred to in your letter is a "television screen or other device of a similar nature." Although the system's monitor is designed to receive signals only from a dedicated video camera, one component of the system is a monitor or screen which receives a signal and displays certain images on that monitor. Thus, if such monitor is visible to the driver, the use of the system is prohibited by e14-105.

Support for this opinion is found in the bill's legislative history. In 1984, the legislature amended e14-105 to permit the installation and use of a "video display unit utilized for instrumentation purposes." During the Senate debate on P.A. 84-215, the Act that amended e14-105, Senator DiBella remarked that:

This is a piece of legislation that has been requested by the Department of Motor Vehicles to bring into compliance the law with respect to much of the video display gadgetry that is used on the instrumentation on new automobiles. Given the fact that television or video display screens for televisions are very restrictive with respect to the use in vehicles, the video display terminals for instrumentation create a conflict between the legislation as it stands and this being amended. This will require the video display instrumentation equipment to be utilized without being in conflict with the television display legislation that prohibits televisions being viewed by the driver.

27 Sen. Proc. pt.3, 1987 Sess. 1087-88 (April 11, 1987), (Remarks of Sen. DiBella).

In a March 14, 1984 public hearing of the Transportation Committee, Peter Rosso, on behalf of the Department of Motor Vehicles, provided testimony concerning that bill as follows:

An Act Permitting the Use of Video Display Units in Motor Vehicles is our bill, currently some of the higher priced vehicles have video display units which give you the gas mileage while driving, etc. The current statute provides that no such units be displayed in the front seat of a car in response to several years ago the fad of putting televisions in automobiles. This just allows the use of the video displays that come with the automobiles.

Conn. Joint Standing Committee Hearings, Transportation, 1984 Sess., p. 585.

It seems clear that if the legislature deemed it necessary to amend e14-105 to permit the use of video units which display instrumentation information, the video monitoring system referred to in your letter is a "television screen or other device of a similar nature", the use of which is likewise prohibited by e14-105.

Very truly yours,

CLARINE NARDI RIDDLE

ATTORNEY GENERAL

Margaret Quilter Chapple

Assistant Attorney General

CNR/MQC/kl

1 You have not requested that we advise you whether the use of such equipment in law enforcement vehicles is prohibited, and this opinion does not deal with that issue.