People v. Acosta (1991)
Facts:
Acosta, driving a stolen car, led police on a forty-eight mile chase. Two police helicopters, assisting in the chase, collided, killing three people. An expert testified that he had never heard of a midair collision between two police helicopters tracking a ground pursuit, and that the pilot of one of the helicopters broke FAA regulations. Acosta was convicted of murder, but claimed that a collision between helicopters was not a foreseeable result of his conduct, and that the pilot’s violation of FAA guidelines was a superseding cause of the deaths.
Issue:
What standard of proximate causation should the court use to determine if a defendant’s actions proximately caused the harm?
Rule:
The “highly extraordinary result” standard should be used. The standard excludes extraordinary results, is simply stated, and allows the trier of fact to determine the issue on the particular facts of the case using common sense. This standard does not involve the defendant’s state of mind, but focuses on the objective conditions present when he acts.
