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13. FAILURE TO YIELD Gilmore v. State, 242 Ga.App. 470, 530 S.E.2d 221 (February 22, 2000). Evidence supported less-safe DUI conviction, but conviction for failure to yield reversed; “the trial court erred in denying Gilmore's motion to quash the citation on the charge of failure to yield and in denying his motion for directed verdict on that charge. Gilmore maintains that the Uniform Traffic Citation charged Gilmore with ‘failure to yield right of way, OCGA § 40–6–72(c).’ [fn] OCGA § 40–6– 72 pertains to stop signs and yield signs, and it includes a number of ways in which the statute may be violated. The UTC is tantamount to a formal accusation. Majia v. State, 174 Ga.App. 432, 433(1), 330 S.E.2d 171 (1985), aff'd, 254 Ga. 660, 333 S.E.2d 834 (1985). ‘Where a crime may be committed in more than one way, the failure to charge the manner in which the crime was committed subjects the indictment or accusation to a proper special demurrer. [Cits.]’ Haska v. State, 240 Ga.App. 527(1), 523 S.E.2d 589 (1999). The UTC charging Gilmore with failure to yield did not inform Gilmore how he violated the statute. Moreover, [Trooper] Fagan admitted on the stand that he should have charged Gilmore with violating OCGA § 40–6–73, not OCGA § 40–6–72, because no ‘yield’ sign was present at the intersection and OCGA § 40–6–72(c) applies only when one is present. It was therefore subject to a special demurrer. Although denominated a motion to quash, the motion filed was a special demurrer, and it was filed before arraignment, as required by Uniform Superior Court Rule 31.1. Compare Haska, supra.” 14. FAILURE TO YIELD TO PEDESTRIAN State v. Ogilvie, 292 Ga. 6, 734 S.E.2d 50 (November 5, 2012). Reversing 313 Ga.App. 305, 721 S.E.2d 549 (November 9, 2011), and reinstating convictions for vehicular homicide, second degree, and failure to yield to pedestrian. Trial court properly declined to charge jury on defense of accident. 1. Contrary to Court of Appeals, “‘strict liability’ traffic offenses are not offenses with no criminal intent element. They do not require the specific intent or wrongful purpose that is an element of other crimes, but they do require the defendant to have voluntarily committed the act that the statute prohibits, which typically involves driving at a particular time and place (e.g., through a red light, see OCGA § 40–6–20(a)) or in a particular way (e.g., too fast, see OCGA § 40–6–181).” Accord, Smith v. State , 319 Ga.App. 164, 735 S.E.2d 153 (November 30, 2012). 2. Defense of accident may apply in strict liability offenses “only where there is evidence, however slight, that the defendant did not voluntarily commit the prohibited act. Contrary to Ogilvie's assertion, this does not eliminate the accident defense in traffic offense cases. The defense must be based, however, on evidence that the prohibited act was committed involuntarily, for example, because of an unforseeable physical ailment or external force. Cf. Smith v. State, 250 Ga.App. 532, 536–537 (552 S.E.2d 499) (2007) (holding that a justification instruction was required on a failure to maintain lane charge based on evidence that the defendant accelerated and hit a utility pole to avoid an armed attack); Sapp v. State, 179 Ga.App. 614, 615 (347 S.E.2d 354) (1986) (holding that a charge on accident was required in a prosecution for obstructing a police officer based on the defendant's testimony that she obstructed the officer when she fell due to illness).” Thus, on the failure to yield to a pedestrian charge here, for example, “[a] charge on accident is appropriate for this crime only when there is evidence that the defendant did not voluntarily drive into the crosswalk.” 3. Defendant’s claim that child suddenly ran in front of her did not state a defense of accident. “If Ogilvie had been indicted for a crime that required her to have intentionally or maliciously hit the child, like murder, see OCGA § 16–5–1, this evidence would have supported an accident instruction, because it would tend to show that she did not act with the requisite “criminal ... intention.” OCGA § 16–2–2. As explained above, however, that was not the type of intent required to commit a strict liability traffic offense.” Rather, the defense raises an issue of proximate cause with regard to the vehicular homicide charge. “In the language of § 40–6–393(c), the evidence raised the issue of whether Ogilvie's alleged violation of § 40–6–91 was ‘the cause of [the child's] death.’ The trial court committed no error in this regard, however, giving the jury a full charge on proximate cause, in addition to charging the relevant language of those two statutes.” “Cause” here means “proximate cause,” citing State v. Jackson, 287 Ga. 646 (697 S.E.2d 757) (2010). Glass v. State, 267 Ga.App. 129, 598 S.E.2d 857 (April 19, 2004). OCGA § 40-6-91, relating to failure to yield to pedestrians, applies regardless of whether the cross-walk in question is controlled by a pedestrian-controlled signal. 15. FLEEING AND ATTEMPTING TO ELUDE McNeely v. State, 296 Ga. 422, 768 S.E.2d 751 (January 20, 2015). Evidence supported passenger’s convictions as a party to felony murder, fleeing and eluding, reckless driving, and related offenses. Contrary to defendant’s assertion, convictions weren’t based solely on testimony of accomplice/driver, but were supported by at least slight circumstantial evidence. Driver was recklessly speeding away from officers pursuing defendant, who had been caught shoplifting. Defendant assaulted an officer in her escape, and was on parole for prior shoplifting offenses. These circumstances corroborated driver’s testimony that defendant demanded that she not stop for police or stop at intersections, resulting in a fatal collision.