A driver waiting to turn left may enter an intersection on green, pause for oncoming traffic, and see the signal change before a safe opening appears. A later collision cannot be resolved from the signal color alone. The evidence must show when each vehicle entered, what each driver could observe, and whether the turn could be completed with reasonable care.

Ward does not create an automatic rule against a driver completing a left turn; it shows why entry into the intersection, signal phase, lookout, oncoming traffic, timing, and opportunity to avoid a collision must be resolved from the evidence.

Ward involved conflicting accounts and a left turn

In Ward v. Carmona, 368 N.C. 35 (2015), the North Carolina Supreme Court reviewed a collision between a left-turning vehicle and an oncoming vehicle at a signal-controlled intersection. The evidence conflicted about when the turning driver entered the intersection, whether the oncoming vehicle could be seen, and the signal color when the oncoming driver entered.

A jury found negligence attributable to both drivers, and the plaintiff did not recover. The Supreme Court affirmed because the record contained evidence from which the jury could reach those findings. The holding is tied to that trial record; it should not be converted into a presumption that both drivers are negligent whenever a left turn is completed after a light changes.

Entering on red is different from clearing an intersection

G.S. 20-158 directs a vehicle facing a steady red circular signal to stop and not enter the intersection, subject to the statute’s stated exceptions. Ward explained that a driver who entered while the light was green could complete the turn to exit the intersection if the driver maintained a lookout and exercised reasonable care. A driver who had not entered when the light turned red had a duty to stop.

The distinction makes the intersection boundary and time sequence material. A witness saying only that the turn occurred “on red” may not establish whether the turning vehicle first entered on green, remained within the intersection, or entered only after the red signal appeared.

The left-turn statute adds a separate movement question

G.S. 20-154 addresses starting, stopping, and turning movements and requires reasonable safety before a vehicle turns from a direct line. Signal compliance and reasonable care during the turn are related but separate inquiries.

  • Stop bar, crosswalk, curb lines, lane geometry, intersection boundary, turn path, vehicle positions, and each point of entry measured or identified
  • Signal phase and timing records, sequence, camera or video time, witness viewpoint, clock accuracy, and any conflict among sources
  • Turning driver’s position, lookout, visibility, obstruction, oncoming traffic, perceived gap, speed, steering, braking, and available escape path
  • Oncoming driver’s signal, speed, distance, lookout, braking, lane, visibility, and time available after the turning vehicle became observable
  • Citation, crash-report entry, witness account, photograph, video, event data, traffic-engineering record, and reconstruction opinion attributed to its source

Keep the straight-through green-light question separate

The related guide asking whether a green light eliminates a driver’s lookout duty addresses a driver proceeding straight on green and the facts that may provide notice that another vehicle will not obey its signal.

Rosensteel Fleishman Car Accident & Injury Lawyers provides general information about Charlotte car-accident claims involving disputed intersection responsibility. Signal compliance, lookout, right of way, negligence, contributory negligence, causation, and damages depend on the complete evidence and current law.

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