Similar in Ontario that it's the fault of the motorist:

No person shall,
(a) open the door of a motor vehicle on a highway without first taking due precautions to ensure that his or her act will not interfere with the movement of or endanger any other person or vehicle; or

(highway is essentially anywhere vehicles are intended to go)

Whether this means anything is dubious:

Friday, July 18. 9:50 am. A 28 year-old cyclist was killed on University Ave. at Dundas St. by a driver who opened his door without looking. The driver received a ticket for $105.00 and 2 points. One week after his death, on Friday July 25, ARC organized a memorial for the cyclist. The monthly Critical Mass ride stopped at the site for two minutes of silence, bikes held aloft.

That being said, maybe the driver isn't the only culprit

http://www.respect.to/pipermail/arca...04/000212.html