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From a law standpoint, I'm fairly sure that the guy in the stolen car would have had to be capable of making a reasonable assumption that that crash could happen due directly to his actions to make the liability stick.
As far as my opinion, he should not be held liable. The fault of the crash lays in one or both of the helicopter pilots. As pilots, they are responsible for keeping their vehicle out of the way or other airborne vehicles.
That guy's only crime was stealing a car.
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