Night, day, twilight - a bicyclist can only increase their likelyhood of surviving their trip by adding reflectors and wearing bright clothing.
It's pretty rare for somebody who hits a deer to be charged with reckless driving, so it's not like there is actually an absolute responsibility to never out drive your headlights.
Besides the legal aspects, anyone riding a bike after dark without any illumination is being irresponsible. Whether the car is at fault or not, it's not going to be the guy in the car who dies from it.
A car with high beams cresting a hill behind you. A car with high beams cresting the hill in front of you. An animal. A drink. A radio station change. A text message.
Reflectors make that big of a difference; they don’t look or move naturally, and thus play well to our night vision strengths, even to a distracted driver.
You'd still be criminally at fault, and if you can't stop in time for a cyclist you're over-driving your headlights, but the cyclists would be well served by buying a back light for visibility. Keep in mind that wild animals can't, and they'll have roughly the same visibility as the cyclist.