People v. Acosta
California Court of Appeal, 4th Appellate District
284 Cal. Rptr. 117 (1991)
After Acosta fled police in a stolen car, leading a reckless 48-mile ground chase, police helicopters from multiple jurisdictions tracked his movements from the air, and two helicopters collided due to erratic maneuvering, killing three occupants; Acosta was convicted of second-degree murder for their deaths, with an FAA expert unable to explain the erratic helicopter movements or recall any similar prior midair collision.
Whether an injury must be the actual result of an act for the act to be considered the proximate cause of the injury, and whether a defendant acts with implied malice if the defendant consciously disregarded a high probability that death would result from the defendant's act.