Summary of People v. Acosta, Court of Appeal of California (1991)
Defendant: Acosta; acosta was discovered in a stolen car and he gave the police a 48 mile chase during which he was involved in highly reckless driving. Unfortunately, two of the police helicopters which were chasing Acosta crashed in the air and three police officers were killed as a result of the crash. During the trial, an expert testified that the crash was a result of pilot’s negligence. But still the defendant was convicted for second degree murder. Now the defendant appeals.
Issue: 1. Was the crash a result of defendant’s acts? 2. Was the crash foreseeable to a reasonable person? 3. Is there sufficient evidence of malice on the part of the defendant?
Holding: 1. Yes 2. Yes 3. No
Key Facts: In order to have causation, the prosecutor has to prove that the defendant’s act was the “actual cause” of the victim’s injury. Also, in this case, the court used the objective and not the subjective standard to determine foreseeability of the event.
Legal Reasoning: The court determined that had the defendant never drove away from the police, the helicopters were not going to be involved in the crash. The court further determined that the fact that two police helicopters had never crashed in a chase before does not take away the forseeability of such event occurring in the mind of a reasonable person. But the court held that a jury will never find sufficient evidence of malice on the part of the defendant, so conviction was reversed.