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to those charges,” including driving without insurance (40-6-10(b)) and leaving the scene of an accident (40-6-270), even though those offenses require specific knowledge (of the lack of insurance or the accident). Court’s pattern charges on evidence of intent, and the fact that intent will not be presumed, were sufficient. Charge about the specific knowledge requirements of the offense in question would seem to be a best practice, if not mandatory. Lawrence v. State, 257 Ga.App. 592, 571 S.E.2d 812 (September 26, 2002). Conviction for leaving scene reversed; evidence failed to show that defendant knew he had damaged victim’s car. “It is not absolute and positive knowledge which must be shown, but rather only that the circumstances were such that a reasonable person would have believed that an accident had occurred resulting in ... damage ... to another.” But see McKay v. State , 264 Ga.App. 726, 592 S.E.2d 135 (November 26, 2003) (Evidence was sufficient to convict defendant for leaving scene of accident despite defendant’s claim that he could observe no injury to victim-pedestrian, and defendant’s car was not damaged). 25. MOTORCYCLE HELMET VIOLATION Dowis v. State , 243 Ga.App. 354, 533 S.E.2d 434 (April 4, 2000). Conviction for violating motorcycle helment law affirmed; defendant’s cloth bandanna clearly doesn’t comply with standards for protective headgear set by Board of Public Safety in Ga. Comp. Rules & Regs., Department of Public Safety, Chapter 570-13, Specifications for Protective Headgear for Vehicular Users. “The regulations require headgear to consist of ‘a hard, smooth outer surface containing the necessary means of attenuating impact energy and resisting penetration,’ Regulation 570-13-.03(1), and to ‘exhibit a minimum level of shock absorbency upon impact with a fixed, hard object.’ Regulation 570-13-.03(2).” 26. MOVE-OVER VIOLATION Van Auken v. State, 304 Ga.App. 802, 697 S.E.2d 895 (July 6, 2010). Defendant’s conviction for “move over” violation affirmed; evidence supported conviction. “Based upon the testimony of the sergeant and the video recording, the jury was entitled to find that Van Auken, approaching in the right traffic lane, would have been able to see the patrol car with flashing blue lights activated while it was still stationary on the right shoulder of the highway. Additionally, the jury could reasonably infer from the evidence that Van Auken had an opportunity to slow down or change lanes before the patrol car started to move, but failed to do so, with the result that he nearly struck the patrol car once it began to slowly merge into the right traffic lane. Under these circumstances, a rational fact finder was authorized to find Van Auken guilty beyond a reasonable doubt of violating the ‘move-over’ statute.” 27. NOISE VIOLATIONS Jackson v. State, 297 Ga.App. 615, 677 S.E.2d 782 (April 23, 2009). Trial court properly denied defendant’s motion to suppress; stop was supported by probable cause to believe that defendant had violated “OCGA § 40-6-14(a) which makes it a misdemeanor for anyone ‘operating or occupying a motor vehicle on a street or highway’ to operate a sound-making device in a car ‘so that the sound is plainly audible at a distance of 100 feet or more from the motor vehicle.’” Defendant argues that the code section doesn’t apply to his vehicle, parked at a convenience store, but “OCGA § 40-6-3(a)(2) states that ‘[t]he provisions of this chapter shall apply to a vehicle operated at shopping centers or parking lots or similar areas which although privately owned are customarily used by the public as through streets or connector streets.’ Here, it was reasonable for the officer to believe that OCGA § 40-6-14(a) applied to the parking lot of the convenience store/gas station where Jackson's vehicle was parked, and the officer's investigatory stop of Jackson's vehicle was justified by a reasonable suspicion that he was operating his vehicle in violation of that Code section.” 28. OBEDIENCE TO AUTHORIZED PERSONS DIRECTING TRAFFIC Williams v. State, 334 Ga.App. 195, 778 S.E.2d 820 (October 19, 2015). Physical precedent only. Obstruction and related convictions affirmed; trial court properly denied motion to suppress. Officer had articulable suspicion to stop defendant who refused to stop for other officers manning roadblock, thus violating OCGA § 40-6-2, “obedience to authorized persons directing traffic,” “which provides that ‘[n]o person shall fail or refuse to comply with any lawful order or direction of any police officer ... invested by law with authority to direct, control, or regulate traffic.’” “The statute does not define ‘lawful order,’ and we have had little occasion to construe its meaning. [fn] We are guided, however, by the conclusions of courts in other jurisdictions interpreting nearly identical statutes that a ‘lawful order’ means ‘an order within the officer’s scope of responsibility in directing traffic.’ State v. Gates, 60 Ohio Misc. 35, 395 N.E.2d 535, 537 (Ohio Misc., 1979); [other cits.]. Applying this definition here, Williams violated OCGA § 40–6–2 by ignoring the ‘stop’ commands of the officers on the north side of the intersection who were performing the police function of directing traffic. The south-side officer’s observation of this violation justified his stop of Williams’s vehicle.”

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