What is the test for "willful misconduct" in a motor vehicle accident?

Willful misconduct is "'"'an aggravated form of negligence, differing in quality rather than degree from ordinary lack of care' [citation]."'" (Berkley v. Dowds (2007) 152 Cal.App.4th 518, 526.) To establish willful misconduct, a plaintiff must prove the basic elements of a negligence cause of actionduty, breach of duty, causation, and damageas well as the following additional elements that raise the negligent actors' acts or omissions above a basic want of ordinary care: "'"(1) actual or constructive knowledge of the peril . . . , (2) actual or constructive knowledge that injury is a probable, as opposed to a possible, result of the danger, and (3) conscious failure to act to avoid the peril."'" (Id. at p. 526, 528.)