Frost faced a less-safe DUI charge after declining a breath test administered under Georgia law. The State offered evidence of two prior intoxication-related driving incidents, one with circumstances notably similar to this arrest. The trial court found the evidence relevant to knowledge under OCGA § 24-4-417 (Rule 417), but the Georgia Court of Appeals held that the statute applied only in a narrower situation involving a defendant’s claimed misunderstanding of testing. The Georgia Supreme Court reversed. It held that Rule 417 is a Georgia-created rule of inclusion for DUI prosecutions. Prior DUI evidence may help establish an accused’s knowledge or planning, or rebut mistake or accident, when the accused declined a required test; this can be true even if the defendant offers no explanation for the current refusal and also declined testing on earlier occasions. Such incidents can show that the accused knew alcohol affected driving and that a test could reveal intoxication, giving context to a later refusal. Frost’s prior incidents were relevant because both involved impaired driving and requests to take a test, and one closely resembled the current circumstances. The Court reversed the Court of Appeals and left for another case the question how OCGA § 24-4-403 limits Rule 417 evidence.