People magazine said photographers captured Bynes allegedly backing into a curb near a nightclub while appearing engrossed in sending text messages while behind the wheel.
Texting while driving is illegal in California without a hands-free device, People noted, and one unidentified paparazzi added that she allegedly had driven "right through a stop sign" without even looking up.
The alleged gaffes occurred just a few days after the 26-year-old Bynes was arrested for drunken driving, the report said.
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