According to 49 CFR 571 - FEDERAL MOTOR VEHICLE SAFETY STANDARDS a trailer is defined as "Trailer means a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle."
Now I know you are going to say that a TOAD is not designed for being drawn by another motor vehicle. As soon as you but a TOW bar on a motor vehicle you have changed the design of the motor vehicle such that it is not designed to be towed. Please stop trying to convince people that they don't need a braking system in a TOAD just to prove your point. Federal law says it is a trailer so if you need a brake on a trailer in a state you need it on your TOAD.
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