How have courts interpreted "accident" as an instruction in a motor vehicle case?

Several days before defendant filed his opening brief, People v. Anderson (2011) 51 Cal.4th 989 held that "accident" is only a variation on a defense theory that a defendant lacked intent, and thus constitutes a "pinpoint" instruction on which a court has a duty to instruct only on request. (Id. at pp. 996-997.) Defendant acknowledges in his reply brief that we are bound to reject his argument as a matter of state law. He therefore simply asks to preserve the issue for possible federal review.