Interpretation ID: aiam3760
117 Aldershot Lane
Manhasset
NY 11030;
Dear Mr. Lampeas: This is in reply to your letter of October 13, 1983, concerning th legality under Federal laws of your patented device, the 'Trunk Truck.' It appears from the material you enclosed that the device extends in twin booms from the rear of the car, and that a stop lamp or taillamp is mounted at the end of each boom (you refer to it as a 'natural extension' of these lamps).; Under the National Traffic and Motor Vehicle Safety Act, no perso (except the vehicle owner) may modify a vehicle so that equipment that is on the vehicle pursuant to a Federal motor vehicle safety standard is 'rendered inoperative in whole or in part.' Therefore, you must assure yourself that all requirements of Federal Motor Vehicle Safety Standard No. 108 continue to be met with respect to rear lighting. This would include not only the lamps at the end of the booms, but those remaining on the car. In addition to stop lamps and taillamps, rear lighting includes, (sic) turn signal lamps, back up lamps, and license plate lamps. As on other load-bearing vehicles, such as boat trailers, these lamps should continue to be visible even with a load installed.; You should also ask the States whether such a device is legal. State have jurisdiction over the use of motor vehicles within their borders.; Sincerely, Frank Berndt, Chief Counsel