A Major Legal Win Supporting Out-of-State Reciprocity & Proper Vehicle Classification
A recent case in the Town of Rotterdam, New York, provides a powerful example of why proper vehicle classification matters—and why many citations issued against Montana-registered quadricycles are legally unsustainable once examined under the correct statute
In People of the State of New York v. Jeremy M. Tretts (Dec. 2025), the court dismissed a charge of Unlawfully Operating an ATV on a Highway after determining that the vehicle involved was not an ATV under New York’s own statutory definitions. This outcome reinforces what we frequently educate clients, attorneys, and law enforcement agencies about:
👉 Most modern side-by-sides and quadricycles—especially Montana-registered units—do not meet the statutory definition of an ATV in many states.


Below is a breakdown of why the court dismissed the charge and why the decision was straightforward once the law was properly applied.
1. THE ENTIRE CASE HINGED ON ONE LEGAL QUESTION
To convict the defendant under VTL §2403, the State had to prove:
The vehicle operated was an ATV as defined under New York’s Vehicle & Traffic Law.
If the vehicle did not meet that definition, the charge could not stand—regardless of where the vehicle was registered.
2. NEW YORK’S LEGAL DEFINITION OF AN ATV IS VERY SPECIFIC
New York’s VTL §2281(1)(a) defines an ATV as:
“Any self-propelled vehicle manufactured for sale for off-highway use provided that it does not exceed 70 inches in width or 1,000 pounds dry weight.”
This weight limit is absolute.
There are no exceptions, no discretionary factors, and no officer-interpretation allowed.
3. THE MONTANA TITLE AND REGISTRATION MADE THE CASE UNBEATABLE
The defense presented certified documents from the State of Montana, including:
- A Certificate of Title, and
- A Montana Registration Certificate
These documents showed the vehicle had a dry weight of 2,015 pounds—over double the maximum weight allowed for an ATV under New York law.
Therefore:
- It could not legally be considered an ATV in New York
- The ATV-specific statute (VTL §2403) did not apply
- The citation was invalid as a matter of law
Once the weight threshold was verified, the case was effectively over.
4. THE COURT FORMALLY DECLARED: THE VEHICLE IS NOT AN ATV
The judge’s written decision clearly states:
“This Court finds that the vehicle is not an ATV as defined by the VTL…”
This finding destroys the core requirement of the prosecution’s charge.
Without an ATV, there is no ATV violation, and no conviction is legally possible.
5. WITH NO LEGAL BASIS FOR THE CHARGE, THE CASE WAS DISMISSED
The judge concluded:
“…the instant charge cannot be sustained as filed and is hereby dismissed.”
All remaining arguments by the prosecution were deemed either irrelevant or unsupported.
6. WHAT THIS CASE MEANS FOR OWNERS OF MONTANA-REGISTERED QUADRICYCLES
This outcome aligns with what we have long maintained at MontanaTags.com:
✔️ Most modern quadricycles, UTVs, and side-by-sides exceed the statutory weight limit for ATVs
✔️ Therefore, they are not ATVs under many state laws
✔️ Charges based on ATV-specific statutes frequently fail in court
✔️ Montana registration is recognized throughout the U.S. under standard reciprocity principles
This case is yet another example of how courts consistently uphold:
- Proper statutory interpretation
- Recognition of Montana registrations
- The legality of operating Montana-registered quadricycles when compliant with general vehicle laws
7. WHY THIS WAS A SIMPLE, CLEAN LEGAL WIN
The defense prevailed because:
- The statutory definition was unambiguous
- The Montana paperwork provided exact vehicle specifications
- The weight exceeded the limit by more than 1,000 pounds
- The prosecution’s case relied on an assumption that was objectively false
- Once classification failed, the entire charge collapsed
In other words, the facts and the law were on the defendant’s side from the beginning.
CONCLUSION
This New York ruling reinforces a growing trend across the country:
When courts apply the correct legal definitions, Montana-registered quadricycles are consistently found to be outside the scope of ATV restrictions.
For clients, attorneys, and industry professionals, this case serves as a textbook example of why:
- Correct classification matters
- Montana registrations are legally valid
- Many citations are issued based on misunderstanding, not law
MontanaTags.com will continue to educate the public, support the street-legal movement that it began, and provide accurate legal resources for quadricycle owners nationwide.
