“...was he familiar with this route? Had he driven it before...”
Hell’s bells! I’ve driven hundreds of thousands of miles on roads I’d never been on before. It’s not relevant. This clown is a mess, that’s all. Give him the maximum sentence + 10 more years for laughing. See how funny that is.
I agree with everything that you said. I only raised it to rebut the potential issue that the barrier was missing a reflector. It will be hard for his lawyer to argue that that was an important factor if he had been driving that route for months .. years? .. and never had a problem before.