Wigmore, writing in 1911, said: "The general question... whether an injury caused by the defendant while violating a [criminal] statute is actionable per se is a troublesome one, open to much argument, and not yet settled by any generally accepted principle."
William T. Muse,
Negligence Per Se and the Virginia Motor Vehicle Code,
U. Rich. L. Rev.
Available at: https://scholarship.richmond.edu/lawreview/vol1/iss1/4