Carter was seriously injured during a testing crash at Phoenix International Speedway in November 1977. The injuries left him with a permanent disability in one of his legs that hampered his ability to perform well on road courses. He still ran very well on ovals. He made his return to racing at the end of March in 1978, winning a USAC Sprint race at the paved five-eighths mile Indianapolis Raceway Park on Saturday night and at the high-banked half-mile Winchester Speedway the next day – his first races back in the cockpit of a racecar.