Virginia, it is easier to prosecute road rage as reckless driving instead of aggressive driving simply because the burden of proof does not require intent to successfully convict. It is likely that those causing serious injury or death during road-rage incidents will suffer more serious penalties than those applicable to similar outcomes from simple negligence. In April 2007, a Colorado driver was convicted of first-degree murder and sentenced to two consecutive life terms for causing the deaths of two motorists in November 2005. Fourteen U.S. states have passed laws against aggressive driving. Only one state, California, has turned "road rage" into a legal term of art by giving it a particular meaning. In Virginia, aggressive driving is punished as a lesser crime (Class 2 misdemeanor) than is reckless driving (Class 1 misdemeanor). Historical antecedents in the U.S. In 1854, a satirical article describing a hell-bent railroad engineer named "Joe Smashup" intentionally ramming other locomotives appeared in U.S. newspapers. U.S. rankings A 2007 study of the largest U.S. metropolitan areas concluded that the cities with the least courteous drivers (most road rage) are Miami, Phoenix, New York, Los Angeles and Boston. The cities with the most courteous drivers (least road rage) are Minneapolis, Nashville, St. Louis, Seattle and Atlanta. In a 2009 AutoVantage survey, New York, Dallas/Fort Worth, Detroit, Atlanta and Minneapolis/St. Paul were rated the top five American cities for road rage. See also Bike rage Air rage Police brutality Riot Gang war Carjacking Motor vehicle theft Street racing Aggressive driving Drive-by shooting Car chase Traffic stop Traffic ticket Sheriff Police Border guard Security police Traffic police State police Traffic guard Traffic warden Highway patrol Joyride Law enforcement Motor Mania Citations General sources Controlling Road Rage: A Literature Review and Pilot Study Prepared for The AAA Foundation for Traffic Safety By Daniel B. Rathbone, Ph.D. Jorg C. Huckabee, MSCE June 9, 1999 Road Rage: Causes and Dangers of Aggressive Driving (transcript of a portion of the official hearing record of the Committee on Transportation and Infrastructure – 1997) Summary Table on Aggressive Driving Laws , National Highway Traffic Safety Administration Survey of the States – Speeding , Governors Highway Safety Association Further reading External links U.S. Study: Road Rage and Aggressive Driving (2019) Driving Hazardous motor vehicle activities Traffic law Crime Crimes Criminals Violent crime Rage (emotion) Road safety Violence