The reckless disregard standard of care, codified in Vehicle and Traffic Law § 1104(e), applies when a driver of an authorized emergency vehicle involved in an emergency operation engages in the specific conduct exempted from the rules of the road by § 1104(b). Any other injury-causing conduct of such a driver is governed by the principles of ordinary negligence.
Edwards v. Menzil, NY Slip Op 04728 (2d Dep't August 26, 2020)