A North Carolina appeals court found that a passenger in an automobile who grabbed the steering wheel while the vehicle was in operation was not in legal possession of the car in North Carolina Farm Bureau Ins. Co. v. Nationwide Mut. Ins. Co., No. COA04-348, 2005 WL 350575 (N.C. App. Feb. 15, 2005).

Charly Simms was driving a car owned by her mother, Betty, with her friend, Reagan Mason as a passenger. As Charly approached a weigh station, Regan grabbed the wheel and attempted to steer the car into the station. Charly tried to maintain control by steering back to the left, but she struck another car as she swerved. The driver of the other car, Thomas Graves, was killed in the collision.