News outlets are reporting that the bicyclist who lost her life in a crash in the West Loop was 39-year old Angela Park of Chicago. The crash occurred at the intersection of Halsted Street and Madison Street. Angela was riding northbound on Halsted where the Halsted Street bike lake has existed for decades. The truck involved in the crash was a dump truck owned and operated by Lakeshore Recycling. The truck was turning right from northbound Halsted onto eastbound Madison when the crash occurred. The exact circumstances of the crash are yet to be determined as there is a major construction project on the southeast corner of Madison and Halsted that has led to frequent changes in the traffic patterns at that intersection. 


The crash was what is known as a “right hook” crash where the truck turned right across the path of the bicyclist. Since the Halsted Street bike lane is to the right of the northbound lane, the truck would cross over the bike lane when turning from Halsted onto eastbound Madison Street. The crash occurred at 7:10 a.m. on a weekday when this area of the West Loop is full of commuters on their way into the Loop for the workday. The presence of a bicyclist on the Halsted Street bike lane is not only common it is constant at this time of the day. Chicago law requires the operators of motor vehicles to utilize “due care” in looking for bike traffic. 


In addition, a “right hook” is strictly prohibited by law.  In Chicago the Municipal Code addresses right hooks. Section 9-16-020 specifically prohibits right turns in front of bicycles. The infographic below details right-hook and left-hook bicycle crashes. The Chicago bicycle law states:

When a motor vehicle and a bicycle are traveling in the same direction on any highway, street, or road, the operator of the motor vehicle overtaking such bicycle traveling on the right side of the roadway shall not turn to the right in front of the bicycle at that intersection or at any alley or driveway until such vehicle has overtaken and is safely clear of the bicycle.” 

Based on the reports, it appears that the operator of the truck also acted contrary to the Illinois Vehicle Code and also Federal requirements. These requirements provide that 1) the driver of a cement truck like this should “keep a proper lookout” for bicycles but 2) to not turn right until it is safe to do so. It is axiomatic that if a vehicle is “clear” to turn, that a bicycle crash cannot occur.


Here are some of the key laws that apply to a bicycle crash of this nature:

  • 49 C.F.R. Section 383.111 of the Code of Federal Regulations requires a professional driver to recognize and avoid potential hazards at all times around a turning tractor truck. 
  •  Section 11-1003.1 of the Illinois Motor Vehicle Code states that every driver of a vehicle must 1) always exercise care to avoid colliding with pedestrians and bicyclists, and 2) sound their horn to provide warning of an impending impact. 
Legal analysis aside it is important to remember that Angela Park was a member of Chicago’s bicycling community. This is another unfortunate reminder of the need for not only laws and policies that protect bicyclists, but strict enforcement of those laws. This is beyond sad, it is tragic in the scope of the loss against reality that it could have been avoided. Our thoughts and prayers and most sincerely with the family of Angela Park. 
Michael Keating

Michael Keating founded Keating Law Offices in 2008 with the mission of representing individuals and families whose lives have been affected due to the negligence of others. Since that time, he has continuously obtained results on behalf of his clients in courtrooms throughout…

Michael Keating founded Keating Law Offices in 2008 with the mission of representing individuals and families whose lives have been affected due to the negligence of others. Since that time, he has continuously obtained results on behalf of his clients in courtrooms throughout Illinois. He has been the attorney on hundreds of successful cases involving transportation negligence, nursing home negligence and abuse, and premises liability cases. The firm has recovered tens of millions of dollars on behalf of its clients and their families for cases involving personal injury and wrongful death.