People v. Acosta, 284 Cal. Rptr. 117 (Cal. Ct. App. 1991)

Facts: ∆ led police on a 48-mile high-speed chase. Two police helicopters pursuing the chase collided in mid-air, killing three officers. ∆ was charged with second-degree murder for the deaths.
Issue: Whether the helicopter collision was a sufficiently foreseeable consequence of ∆'s flight to satisfy proximate cause.
Rule: Proximate cause is satisfied where the result is a possible (not necessarily probable) consequence that an ordinary person would have foreseen as reasonably likely to flow from the conduct.
Analysis: While the precise pilot error was unusual, the general harm—a fatal accident among pursuing officers—was a foreseeable risk created by leading high-speed pursuit. The pilots' negligence was a dependent intervening cause that did not break the chain. (However, ∆ lacked the implied-malice mens rea for second-degree murder.)
Judgment: Murder reversed (mens rea); causation analysis affirmed.

Reading: pp. 167–73. See Ch. 4—Causation.