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gestures toward her. Thereafter, A.M.A. braked suddenly after telling her passengers to ‘watch this.’” State v. Burrell, 263 Ga.App. 207, 587 S.E.2d 298 (September 12, 2003). A single act of aggressive driving, directed toward four occupants of another vehicle, can be charged as four separate counts of aggressive driving, each naming a different victim, and those victims may be drivers or passengers. “‘A person commits the offense of aggressive driving when he or she operates any motor vehicle with the intent to annoy, harass, molest, intimidate, injure, or obstruct another person’ [emphasis in Court of Appeals decision, not statute]. Notably, the statute does not limit the applicability of the offense as going toward ‘another driver’ ; the legislature could have made this distinction but apparently chose not to. Under OCGA § 40-6-397, the State must show that the indicted acts constituting aggressive driving (in this case, following too closely and overtaking) were committed with the requisite intent directed at a specific person named in the indictment.” By contrast, “reckless driving is not directed toward a specific person,” and thus “the same reckless acts of driving cannot be punished multiple times by simply naming a different ‘person or property’ that the acts allegedly endangered.” Trial court properly quashed multiple counts of indictment regarding reckless driving, but should not have quashed aggressive driving counts. 2. DRIVING IN THE EMERGENCY LANE Payne v. State, 275 Ga. 181, 563 S.E.2d 844 (May 13, 2002). Code section (OCGA § 40-6-50(b)) prohibiting driving in emergency lane is not unconstitutionally vague, although code contains no definition for “emergency lane”; term has a commonly understood meaning: “the portion of the paved highway that is separated from the roadway by the solid white lines that mark the boundaries of the roadway.” 3. DRIVING ON WRONG SIDE OF ROAD Parker v. State, 317 Ga.App. 93, 730 S.E.2d 717 (July 18, 2012). Conviction for driving on wrong side of road didn’t require proof that there was oncoming traffic. 4. DRIVING TOO FAST FOR CONDITIONS Abelson v. State, 269 Ga.App. 596, 604 S.E.2d 647 (September 15, 2004). State need not prove what the speed limit was to convict on charge of driving too fast for conditions. “[A]lthough the State presented no evidence regarding the legal speed limit, there was evidence that while negotiating a curve, Abelson’s car traveled off the roadway after leaving a 216- foot skid mark, that the rear tire wheel was considerably bent, and that Abelson admitted he was ‘showing off for his girlfriend by driving fast.’ Accordingly, there was sufficient circumstantial evidence to support a conviction for driving too fast for conditions. [Cit.]” 5. DRIVING WITH SUSPENDED REGISTRATION Lawson v. State, 313 Ga.App. 751, 722 S.E.2d 446 (January 27, 2012). Evidence supported DUI conviction, but not conviction for driving with suspended registration. OCGA § 40-6-15(a) prohibits knowingly driving on the public roads with suspended registration. “Here, the State failed to offer any evidence from which the jury could reasonably infer that Lawson had either actual or constructive knowledge of the car's registration status. Lawson did not own the car. The evidence shows only that he had been driving it. The State did not show that Lawson inherited the car nor did it present any facts from which the jury could infer that the car had been in his possession, custody, or control for any specific length of time. In fact, the State adduced no evidence establishing to whom the car was actually registered, when the car's registration had been suspended, or for what reason. Lawson's unrebutted testimony established that the car did not belong to him, that he did not know the car was not properly registered, that his sister wanted the car, and that she was supposed to get it registered in her name after their father died.” 6. DRIVING WITHOUT INSURANCE Spence v. State, 263 Ga.App. 25, 587 S.E.2d 183 (September 2, 2003). “[P]olice officers’ testimony that Spence said at the time of his arrest that the car was not insured” was insufficient to support conviction for driving without insurance where defendant produced insurance card at trial and testified that the car was, in fact, insured. “Under the version of OCGA § 40-6-10(a)(5)(A) in effect at the time, a valid insurance card was sufficient proof of insurance of any vehicle for purposes of the statute. See Ga. L. 2000, pp. 429, § § 5, 5A; Ga. L. 2001, p. 1228, § 2A. And although the statute requires a valid insurance card, ‘the [s]tate cannot simply say it does not believe the insurance card is valid and direct the defendant to prove its validity.’ Bailey v. State, 241 Ga.App. 497, 498(1) (526 S.E.2d 865) (1999). Rather, the state has the burden of showing the card was invalid.” Note, law in effect at that time did not require proof of insurance in vehicle.
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