Can a minor under the age of 5 be held liable for negligence in the context of a motor vehicle accident?

Turning to the facts of this case, we note that minors under the age of 5 are, as a matter of law, deemed incapable of negligent acts, i.e., failing to exercise reasonable care under the circumstances. (Christian v. Goodwin (1961) 188 Cal.App.2d 650, 652-654, 10 Cal.Rptr. 507 and cases collected there.) "The proposition that 'An infant may be so very young that no negligence may legally be imputed to him' [citation], is predicated on the principle that a child of very early years is 'incapable of realizing that his heedless conduct might foreseeably lead to injury to another which is the essential capacity of mind to create liability for negligence.' [Citation.]" (Ibid.)