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

plaintiff must demonstrate by clear and convincing evidence that defendant is guilty of something more than negligence; he or she must show reckless, oppressive, fraudulent, or malicious conduct. The latter three categories involve 'intentional, ' 'willful, ' or 'conscious' wrongdoing of a 'despicable' or 'injurious' nature." Delaney v. Baker, 20 Cal.4th 23, 31, 82 Cal.Rptr.2d 610 (2004). "'Recklessness' refers to a subjective state of culpability greater than simple negligence, which has been described as a 'deliberate disregard' of the 'high degree of probability' that an injury will occur." Delaney, 20 Cal.4th at 31, 82 Cal.Rptr.2d 610 (citations omitted). "Recklessness, unlike negligence, involves more than 'inadvertence, incompetence, unskillfulness, or a failure to take precautions' but rather rises to the level of a 'conscious choice of a course of action... with knowledge of the serious danger to others involved in it.'" Delaney, 20 Cal.4th at 31-32, 82 Cal.Rptr.2d 610 (citations omitted).