How have courts interpreted the doctrine of scienter in a motor vehicle accident case?

For example, in People v. Gabriel, 164 Misc.2d 473 (Crim. Ct. Queens County 1995), the court found that the defendant's knowledge that his privilege to drive had been suspended is a question of fact at the time of trial and the satisfaction of Vehicle and Traffic Law 214 is not a prerequisite for the conversion of a misdemeanor complaint to an information. Id. at 476. This case supports the contention that scienter need only be established at trial, and need not be supported by non-hearsay at the pleading stage.