What is the standard for determining wilfulness or wantonness of a defendant in a motor vehicle accident?

It can well be argued that the rigid application of an internal or subjective standard for determination of wilfulness or wantonness of defendant's intent would place an unduly heavy burden upon the plaintiff (see discussion in Van Fleet v. Heyler, supra, 51 Cal.App.2d 719, 727-730, 125 P.2d 586). But this instruction deals with much more than the frame of mind of defendant. It could readily be construed by the jury to charge defendant with all the facts of which the reasonable and prudent man in like position would have been aware, and then to apply the standard of ordinary care to a determination of the frame of mind motivating defendant's actions in such circumstances.