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Cutter v. State, 275 Ga.App. 888, 622 S.E.2d 96 (October 17, 2005). Defendant was convicted of reckless driving and second-degree vehicular homicide. The predicate charge for the vehicular homicide charge was improper lane change. Held, the two charges did not merge, as the reckless driving charge was based on acts other than the improper lane change. Walden v. State, 273 Ga.App. 707, 616 S.E.2d 462 (May 20, 2005). 1. “[E]vidence that Walden’s use of certain prescription drugs while driving caused her to be so tired, drowsy, or otherwise impaired that she was unable to control the truck” was sufficient to convict of reckless driving and hence, first degree vehicular homicide. 2. “[C]harges of reckless driving require proof of criminal negligence,” defined as “not merely such negligence as might render one liable for damages in a civil suit, but recklessness or carelessness of such character as to show a disregard of consequences or a heedless indifference for the safety and rights of others who might reasonably be expected to be injured thereby. [Cits.]” 3. Defendant can be convicted of reckless driving based on drug use even where acquitted of DUI. Hill v. State, 207 Ga.App. 65, 426 S.E.2d 915 (1993). Morrison v. State, 272 Ga.App. 34, 611 S.E.2d 720 (March 8, 2005). Officer could be authorized to stop defendant for reckless driving even though “there were no other persons or cars in the immediate vicinity. Reckless driving does not involve specific, intended victims. ‘Instead, it is the act of driving in such a manner as to demonstrate a reckless disregard for all people or property – generally – whether or not any specific person or property is, in fact, endangered at the time of the indicted act.’ (Footnote and punctuation omitted.) State v. Burrell, 263 Ga.App. 207, 208(2), 587 S.E.2d 298 (2003).” Affirmed on different issue, 280 Ga. 222, 626 S.E.2d 500 (February 13, 2006); overruled on different issue, State v. Slaughter , 289 Ga. 344, 711 S.E.2d 651 (June 13, 2011). Winston v. State, 270 Ga.App. 664, 607 S.E.2d 147 (October 29, 2004). “Reckless driving occurs when a person drives a vehicle ‘in reckless disregard for the safety of persons or property.’ [Cit.] Because ‘the offense of reckless driving may be committed in a variety of ways ..., the State needed only to present evidence showing that [Winston] drove [her] car in a manner exhibiting reckless disregard for the safety of persons or property.’ [Cit.] The state met this burden by presenting evidence that Winston was driving above the speed limit without headlights on a rainy night, was looking down instead of watching the road ahead, and neither sounded her horn nor applied her brakes when she saw [pedestrians] just before she hit them. This evidence was sufficient to support her reckless driving conviction.” Distinguishing Klaub v. State , 255 Ga.App. 40, 564 S.E.2d 471 (2002) (striking pedestrian, without proof of manner of driving, not sufficient to convict for vehicular homicide by reckless driving). Fraser v. State, 263 Ga.App. 764, 589 S.E.2d 329 (October 24, 2003). “[S]peeding, unaccompanied by other traffic violations, can form the basis for a reckless driving conviction if the state presents evidence ‘that a defendant was driving at an excessive rate of speed given the posted speed limit and the driving conditions existing at the time.’ [Officer] testified that Fraser was driving 24 mph above the speed limit on a city street near pedestrians, front yards, and driveways. In addition, Fraser showed signs of impairment due to alcohol consumption. This evidence was sufficient to show that Fraser acted with a reckless disregard for public safety as required for a reckless driving conviction” (emphasis in original). Accord, Travis v. State , 314 Ga.App. 280, 724 S.E.2d 15 (February 22, 2012); Evans-Glodowski v. State , 335 Ga.App. 484, 781 S.E.2d 591 (January 14, 2016). 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.

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