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This public outrage of texting while in control of a vehicle has been fuelled by a number of high-profile cases. In Boston in 2009, a trolley driver was charged with an act of gross neglectfulness when sixty-two people were fatally injured as the driver was distracted by his cellular phone, and one year earlier in California twenty-five folk were killed and 101 folk were hurt when the driver of a passenger train collided with a freight train while the driver was sending a text.