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The person in the car is to blame because the person riding the bicycle would have no way of telling when the car door would be open. the person in the car could have easily looked in the side mirrors and could have seen if someone riding a bicycle was passing by.

Added; The traffic offense charge would be "Opening Door to Traffic."

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Q: Who is at fault if a parked car opens its door a few inches and is hit by bicycle coming from rear?
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