6.18Reckless Driving
“A person who violates [MCL 257.626] is guilty of reckless driving as provided in [MCL 257.626].” MCL 257.626(1).
“Except as otherwise provided in [MCL 257.626], a person who operates a vehicle upon a highway or a frozen public lake, stream, or pond or other place open to the general public, including, but not limited to, an area designated for the parking of motor vehicles, in willful or wanton disregard for the safety of persons or property is guilty of a misdemeanor[.]” MCL 257.626(2).
•M Crim JI 15.15 addresses the elements of reckless driving.
MCL 257.626(2) provides for:
•imprisonment for not more than 93 days; or
•fine of not more than $500; or
•both.
Only applicable sanctions are listed below; accordingly, if a particular sanction is omitted from this section, it is not applicable to this offense. The Offense Code Index for Traffic Violations published by the secretary of state and sourced from the Michigan Department of State Court Manual includes a table detailing traffic offenses and applicable sanctions. See Section 1.41 for more information on abstracting procedures.
•Six points. See MCL 257.320a(1)(e); MCL 257.732(1)(a). See Section 1.42 for more information on points.
•Mandatory 90 day license suspension; license revocation/denial required under certain circumstances. See MCL 257.303(2)(a); MCL 257.319(3)(b). See Section 1.45 for more information on license suspension, Section 1.44 for more information on license revocation, and Section 1.43 for more information on license denial.
E.Issues
“Willful or wanton disregard means more than simple carelessness but does not require proof of an intent to cause harm. It means knowingly disregarding the possible risks to the safety of people or property.” People v Carll, 322 Mich App 690, 695 (2018) (quotation marks omitted). There was “[e]xtensive evidence” showing the defendant “drove in a manner that willfully or wantonly disregarded a high risk of serious injury to the people in his vehicle and other vehicles” where “there was evidence that defendant purposefully drove through a stop sign at high speed without any attempt to brake and that he might even have accelerated into the intersection.” Id. at 696-697.