The Illinois supreme court referred to the lack of bike lane markings or bike route signs as the primary indication that the road was not intended for bicyclists. If the case had been heard decades ago, before bike lanes and routes existed, the court could not have made that argument; everyone expected bicyclists to be using normal travel lanes. Unfortunately, the court bought into the framework created by some of the more enthusiastic bikeway proponents (who define "bicycle transportation networks" in terms of bicycle-specific traffic control devices) that normal roadways are for cars and that bicycling on them is dangerous and unintended even if is legal.

Whether one finds value in bicycle-specific traffic controls or not, I think it is important to avoid this marginalizing framing whenever discussing bicycle transportation. A superior framing is to insist that all roadways are bicycle facilities, intended for use by bicyclists, but that some are more enjoyable than others, and that certain routes have been marked as such to promote bicycling. Some municipalities explicitly adopt such policies, declaring all normal roadways as bicycle facilities in their transportation plans, particularly when they face challenges from a state that refuses to consider bicycling on roads not designated as such.