Section 27315 (d)(1) of the California Vehicle Code (CVC) states, in part, "A person shall not operate a motor vehicle on a highway unless that person and all passengers 16 years of age or over are properly restrained by a safety belt." Under 360 CVC, a highway is defined as "a way or place of whatever nature, publicly maintained and open to the use of the public for purposes of vehicular travel. Highway includes street." So, if the private property included a place that was publicly maintained and intended for vehicular travel, then yes, an officer could issue a seat belt citation on private property.
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