What is the test for intentional or reckless conduct in a motor vehicle accident case?

To satisfy the second element, intentional or reckless conduct, a plaintiff must show either the defendant's conduct was primarily directed at the plaintiff or the defendant was aware of, but acted in reckless disregard of, the plaintiff and of the probability that the conduct would cause severe emotional distress. Christensen v. Superior Court, 54 Cal. 3d 868, 903 (1991) ("It is not enough that the conduct be intentional and outrageous. It must be conduct directed at the plaintiff, or occur in the presence of a plaintiff of whom the defendant is aware.").