People v. Willis

Summary

The Court of Appeals affirmed both convictions, holding that the misdemeanor complaints were facially sufficient to establish reasonable cause to believe defendants knew or had reason to know their licenses were suspended. Because defendants waived prosecution by information, the complaints needed only evidentiary facts supporting reasonable cause, not nonhearsay allegations establishing every element beyond a prima facie showing. The complaints' allegations about DMV records, traffic summons warnings, automatic suspensions, and the officers' observations supplied that basis; the court did not reach an additional reckless-driving challenge.