California, United States of America
The following excerpt is from People v. Miller, B250578 (Cal. App. 2014):
In Rodriguez, for example, the defendant escaped from custody, causing an officer to chase him. (People v. Rodriguez, supra, 69 Cal.App.4th at p. 346.) When the officer tackled the defendant, the officer hit his head on something and was knocked unconscious. (Ibid.) Rodriguez found that although there was evidence the defendant proximately caused the officer's injuries, the record did not establish he directly inflicted them. (Id. at p. 352.)
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