Legal Definition: What Is a Motor Vehicle?

In terms of legal drafting definitions, Black’s Law Dictionary provides:
Motor Vehicle. A vehicle that is self-propelled and not operated by a person outside the vehicle; e.g., an automobile or bus. – Also termed motorcar.
Black’s Law Dictionary 1091 (Bryan A. Garder ed., West Group 8th ed . 2004)
The dictionary cites as examples of motor vehicles "golf carts, bicycles, scooters, motorcycles, mopeds, tri-motors and those trolley cars on university campuses," as well as the more conventional vehicles people encounter in daily travel.
Notably, the definition does not discriminate between those vehicles that are appropriately licensed by state or local authorities and those which are not.

Historical Roots of the Definition

It’s noteworthy that the first definition of "motor vehicle" found in the first edition of Black’s Law Dictionary (1891) is devoid of activity. That initial definition reads: "A vehicle which is self-propelling, as distinguished from one which relies for its motion upon the strength of man; a conveyance for land, drawn by horses or otherwise." Furthermore, not until the 4th edition (1968) is the car even discussed as a "motor vehicle." In the 4th’s definition of motor vehicle, we get our first sense that the typical motor vehicle wasn’t just a horse-drawn carriage with a motor, but a ‘car’ with tires. The term "automobile" was put in parenthesis. In the 7th Edition (1973), "motor vehicle" is defined as "Any self-propelled, wheeled conveyance designed for traveling on land, not operated on rails or tracks." This definition includes, for the first time, the terms ‘wheeled’ and ‘conveyance.’ In the 1968 definition of ‘car,’ there is no reference to wheels. The terms ‘road’, ‘land,’ ‘highway,’ and ‘traveled way’ seem to first show up in the 8th edition (1973), along with a transitional sentence on ‘highway’ that instructs you to move from the term to the article on ‘road.’ Then, finally, in the 9th edition, the definitions of ‘motor vehicle,’ ‘car,’ ‘automobile’, and ‘truck’ are all in their own articles. The definition of ‘car’ in the 6th, 7th, and 8th editions omits any reference to a truck or automobile. This is a startling omission given that the automobile was already commonplace in the United States by then and ubiquitous in the American cultural identity. By 1973, the editors of the Black’s Law Dictionary also added the word ‘garage’ to the dictionary; a common term tied to mobility products and services. This is also the year that Kevin Adams graduated from Texas Tech University School of Law and began working as an insurance coverage attorney, representing insurance companies taking the position that expanded the definition of ‘car’ to find alternatives to coverage for their insureds. Today, the insurance industry continues to struggle with the term ‘motor vehicle’ in its database, and with evaluating coverage for motor vehicles that fly, drive, swim, and float. The increasing frequency of hybrid and electric vehicles with complex electrical systems are all integrated with power trains, generators, and other products and parts. Every year, the definition of ‘motor vehicle’ is challenged in the courts and challenged in corrections to the insurance databases, e.g. proof-of-loss forms, and insurer provided claim software.

Four Key Elements of the Definition

When defining "motor vehicle," Black’s Law Dictionary uses the primary elements of self-propulsion, intended use on public roads, and passenger capacity. A self-propelled vehicle requires that the vehicle has a direct motive power source within the vehicle itself. We find that this is generally satisfied where a vehicle has an internal engine, though an electric motor may as well suffice under some circumstances. The vehicle must have been designed for use on public roadways as opposed to on private property or waterways. Vehicles that were originally designed for off-road use do not constitute motor vehicles even if they move on public roadways. Lastly, passenger capacity of 6 to 10 people according to Black’s is relatively in line with the Pennsylvania statute’s requirement of 9 or less. Black’s provides that touropaneuvers performed along the roads set forth by The Pennsylvania Turnpike are not necessarily a part of public roadways and they find that earlier court decisions erroneously included these moves in determining whether or not a vehicle was a motor vehicle.

Implications of Motor Vehicle Listing

The classification of a vehicle as a motor vehicle has practical significance in the realm of litigation. The most common category of litigation where motor vehicles are at the forefront are insurance claims, particularly under insurance for motor vehicles. New Jersey law requires all purchasers of motor vehicles to purchase automobile insurance policies. N.J.S.A. 17:28-1.4. Insurers are required to offer comprehensive automobile coverage, where the risk of loss is distributed among automobile policyholders.
Depending on the nature of the accident, claims may be filed under first party insurance, for purposes of obtaining PIP coverage in order to pay medical expenses. New Jersey law mandates that motor vehicle insurance policies provide PIP benefits for medical and disability payments for "non-casualty" or first-party claims. See N.J.S.A. 39:6A-3a; N.J.S.A. 17:28-7. No other category of insurance is similarly mandated by New Jersey law. Thus, as a matter of public policy, motor vehicles are afforded special treatment under the law when it comes to injury claims. This is because the State Legislature "found that there was a need to afford the needed medical care to persons who are injured, especially [in accidents] and that such medical care should be provided without regard to fault and without respect to the solvency of the driver, the owner, and the other parties involved in such mishap." Pombonyo v. Bugliari, 160 N.J.Super. 204 (1987) (citing Suter v. Warren Hospital, 142 N.J. Super. 37, 43 (Law. Div. 1976).
As discussed more fully herein, legal disputes may also arise in situations where another individual is responsible for injuries to the driver or a passenger traveling in the insured’s motor vehicle. In that instance, a third-party claim for negligence may be filed against the responsible driver. However, certain risks or injuries are specifically excluded under automobile insurance policies.
Legal disputes may also arise in circumstances where an injured individual is not traveling as a passenger in the insured’s vehicle, but seeks recovery from the insured’s insurer as a third-party claimant. Motor vehicle policies typically contain a liability provision where the insurer agrees to pay damages the insured is obligated to pay due to bodily injury or property damage caused by an accident resulting from the ownership, maintenance or use of an insured motor vehicle. This coverage extends to bodily injury or property damage arising out of the operation or use of a non-insured vehicle if the vehicle is operated with permission of the insured and the vehicle is not owned, hired, rented or borrowed by the insured or any member of the household of the named insured. See Leyva v. Becker, 302 N.J. Super. 152 (App. Div. 1997).

Case Examples of Court Interpretations

The Black’s Law Dictionary definition of "motor vehicle" has been challenged in numerous court cases. In some of these cases, the court found that a literal interpretation of the term as defined was untenable, and the judge adopted a more practical and commercial interpretation. In others, the judges closely applied the definition and determined that it included items not intended to be within the scope of the law being interpreted.
For example, the issue claimant’s counsel argued in the McCulloch v. Interstate Motor Freight System case-namely, whether a trailer is considered a mobile home under the Workers’ Compensation Equity Act (the "Act")-could have been easily avoided if the claimant or his counsel had simply read the definition of "motor vehicle" in Black’s Law Dictionary and understood the actual meaning of the term. In McCulloch, for the first time ever, the Indiana Court of Appeals was firmly asked to address the issue of whether a trailer is a "motor vehicle" within the meaning of the Act, and by extension, whether a trailer is a "residential unit" under the Act. The claimant had not one, but two, vehicles which were both on the jobsite at the time he was injured. The trailer was stored alongside a tractor at the shop. The trailer had obviously been moved to the location for some reason, which no one bothered to gather, but was still attached to the tractor. Ironically, the claimant’s arguments to overturn the Commission’s ruling are the same arguments which might have been more appropriate to defeat an employer’s notice of claim request in a jurisdiction such as Texas, where trailers are included within the Workers’ Compensation definition of "motor vehicle." The claimant argued exactly what the Texas statute requires: he argued that the 6th wheel plate is not used to drive the trailer, the trailer requires another vehicle to load and unload, and the trailer is not intended to be driven on the highways in the immediate neighborhood of the claimant’s worksite. However, the Indiana Court of Appeals, persuasively applied the definition of "motor vehicle," as set forth in Black’s Law Dictionary, to reach a contrary result-namely , that a trailer is a motor vehicle, even if it cannot be driven as is, and must be treated as a residential unit under the Act.
In Donovan v. Federal Bureau of Prisons, the United States Court of Appeals, Third Circuit, adopted and applied the definition of "motor vehicle" contained in Black’s Law Dictionary, reasoning that Congress used the term normally and ordinarily understood as defined in Black’s Law Dictionary thereby confirming the dictionary definition as the prevailing interpretation of the term. In this case, the issue was whether a refrigerator truck, with an engine and permanent attachments that could produce in excess of 400 rotations per minute, was a motor vehicle. To reach this decision, the court looked at the practical application of the word, not just the literal interpretation of the words in the statute, seeking to adopt a definition that did not include refrigerators mounted to a vehicle frame.
In Kessling v. Aon Corporation, the Indiana Court of Appeals was again asked to determine whether a semi-tractor trailer is a mobile home. In reaching its decision the Court also applied the Black’s Law Dictionary definition of "motor vehicle" finding that a semi-tractor trailer was a "motor vehicle" under an Indiana statute defining coverage for fire loss to a trailer parked on a residential premises that was not a permanent residence. The Court held it was immaterial to the determination that the trailer was not only for recreational use, but was housed on a farm, and stated "that which is a motor vehicle is not changed by the additional fact that it may be parked in a lot and used as a rental unit." The court followed the lead of the Donovan court in holding that each vehicle is allowed to operate on the roadways as a fully functional vehicle, regardless of whether there is any fuel in the tanks, and continued that "the fact that the vehicle may not be tailored for travel at speeds greater than five to ten miles an hour does not change the fact that it is a motor vehicle." In other words, the type of vehicle being used is what determines whether it is covered under the statute, not the amount of gas in the tank.

Statutory Definition as Compared to Black’s Definition

The definition of "motor vehicle" put forth in Black’s Law Dictionary is not unique. There are numerous statutory definitions of "motor vehicle," and these statutory definitions are quite similar to the broad definition that Black’s Law Dictionary provides. Specifically, Black’s Law Dictionary defines "motor vehicle" as a "vehicle which is self-propelled or propelled by electric power obtained from overhead trolley wires but not operated on rails but not operated on rails." Although this definition is broad, it is consistent with the definitions of "motor vehicle" set forth in statutes in many jurisdictions.
For instance, the Illinois Vehicle Code, 625 ILCS 5/1-146 et seq., defines "motor vehicle" as "every vehicle which is self-propelled or operated by mechanical power, and used upon a highway in the state, excepting motorized bicycles or trucks powered by gas engines rated at 10 horsepower or less." The Vehicle Code goes on to specifically include commercial vehicles as a subcategory of "motor vehicles," defining "commercial vehicle" as "[e]very motor vehicle designed for carrying more than 10 passengers, including the driver, or designed or used for living quarters while being driven upon a highway, or designed for carrying cargo, or operated on a highway for commercial purposes, or for the delivery of goods or merchandise." Illinois applies a similar definition to "motorcycle," which may be relevant in that the term "motorcycle" is also included in Black’s Law Dictionary definition of "motor vehicle."
New Jersey’s statutory definition of "motor vehicle" also parallels that of Black’s Law Dictionary. Specifically, N.J.S.A. 39:1-24 defines motor vehicle simply as a "vehicle which is self-propelled." New Jersey law includes definitions pertaining to various types of motor vehicles such as bus, truck, and van, as well as other categories relevant to this discussion such as "motorcycle" and "multipurpose passenger vehicle." The State of Texas also has several statutory definitions pertaining to motor vehicles, including definitions for passenger car, motorcycle, and truck among others.
There are exceptions in other jurisdictions. The District of Columbia, for example, defines "motor vehicle" as "any motor vehicle of any kind which is self-propelled or propelled by gasoline; motor vehicles with trailers, with or without detachable tires; motor-driven cycles of every kind." The Maryland Transportation Code, Md. Code Ann. Transp. § 11-1501, also provides the following definition: "Motor vehicle means any vehicle which is self-propelled except for vehicles propelled by electric motors used solely for support purposes, including vehicles designed for operation upon a highway which are registered in this State or have been given an identifying number by another state, but does not include a bicycle." Perhaps the most notable exception to the general rule is found in the California Vehicle Code, Cal. Vehicle Code §§ 415 to 528. The term "motor vehicle" is defined generally as "a device by which any person or property may be propelled, moved, or drawn upon a highway, except a device operated exclusively on stationary rails or tracks." However, the Californian legislature appears to define "motor vehicle" in a far more restrictive manner in the California Vehicle Code’s Financial Responsibility Law, also known as the California Motor Vehicle Financial Responsibility Law. The Limitation on Liability, Cal. Civ. Code § 17317 et seq., defines the term "motor vehicle" as "a passenger vehicle of a type required to be registered under the laws of this state which is manufactured in a base year of 1988 or subsequent." Therefore, "motor vehicle" may be defined differently even within the code of the same jurisdiction. The reason for the difference in definitions across states and in the different parts of the same code is that different governmental bodies have different interests and purposes for the definitions that they adopt.

The Future for Motor Vehicle Definition Adaptation

As the auto industry continues to revolutionize itself from traditional internal combustion engine (ICE) vehicles to alternative fuel or powertrain vehicles, the same evolution will impact the definition of a motor vehicle within Black’s Law Dictionary. As the days of ICE vehicles draw to a close, technologies such as electric and other forms of hybrid power will become ubiquitous across the US auto market. Ever ominous on the horizon, the concept of the autonomous vehicle is coming ever closer to reality. Autonomous vehicles will further impact the notion of a motor vehicle , this time from a technology standpoint, as increasingly complex software, sensors, cameras, and computing power will not only contribute to the change in fuel but also the manner in which a driver operates a vehicle. This new technology will impact and continually redefine a motor vehicle, meaning that the definition of a motor vehicle within Black’s Law Dictionary must continually be updated to remain current with everchanging technology and the auto industry.