There are so many cars sold like that though. Toyota, several Lexus, Mercedes, Infiniti, all had hid bulbs in reflectors. From the factory
That's true for early adopters of HID technology and many folks (including some cops) assume if it's in a high-end car, it must be legal. But it was those early attempts to put the HID lamps in reflectors designed for halogen bulbs and the resulting complaints from drivers meeting them head-on that led to DOT review of the issue.