California Vehicle Code § 24802

Vehicle Code
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No lights need be displayed upon a vehicle which is: (a) Parked off the roadway and not in a hazardous position on the highway; or (b) Parked with a wheel within 18 inches of a curb; or (c) Parked within a business or residence district with a wheel within 18 inches of a curb or edge of the roadway.

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