Does intervening criminal activity in a motor vehicle accident constitute a superseding cause?

Negligence alone does not make a third party's intervention a superseding cause. (Rest.2d Torts, 447.) If the intervening act ". . . is a normal consequence of a situation created by the actor's conduct and the manner in which it is done is not extraordinarily negligent" a third party's negligent act does not supersede the liability of the initial actor. (Rest.2d Torts, 447, subd. (c).) Even intervening criminal conduct may not be a superceding cause, thereby breaking the chain of causation.¹⁶ ". . . It is settled, however, that 'If the realizable likelihood that a third person may act in a particular manner is the hazard or one of the hazards which makes the actor negligent, such an act whether innocent, negligent, intentionally tortious or criminal does not prevent the actor from being liable for harm caused thereby.' [Citations.]" (Richardson v. Ham, supra, 44 Cal.2d at p. 777 [citing Rest.2d Torts, 449].) (Italics added.)