In Reclusado v. Mangum (1964) 228 Cal.App.2d 8, the court explained that the "purpose of Vehicle Code section 21701 was to prevent anyone from doing intentionally anything that would unreasonably interfere with the driver in the operation of the vehicle 'in such manner as to affect the driver's control' irrespective of whether such person actually intended to affect the operation or not ... ." (Id. at p. 15.) Reclusado involved the grant of a defense new trial motion on grounds of errors at law in jury instructions. (Reclusado v. Mangum, supra, 228 Cal.App.2d at p. 10.) There, the defendant, a backseat passenger in a vehicle driven by her 15-year-old son who had received his instruction permit days earlier, put her 18-month-old child into the front seat next to her son after which the car went off the road, struck a cement culvert, killed one person and injured the vehicle's occupants. (Id. at p. 12.) The plaintiff sued the driver's mother for negligence in part on the theory that she willfully interfered with the driver so as to affect his control of the car. (Id. at pp. 10, 11.) As relevant here, the trial court instructed the jury on the language of Vehicle Code section 21701 and told them if a party violated that statute, a presumption of negligence arose that could be overcome by other evidence showing that under all the circumstances surrounding the event, the conduct in question was excusable or justifiable. (228 Cal.App.2d at p. 14.) On appeal, the respondent took the position that the statute required "as a prerequisite to liability there must be a physical interference with the driver's operation, with specific intent to affect the operation itself." (Reclusado v. Mangum, supra, 228 Cal.App.2d at p. 15.) The appellate court rejected that position, stating that the Legislature's intention seemed "broader in scope." (Ibid.) It reasoned: "Many acts which the code section is designed to prevent are not accompanied by an actual wish to interfere directly with the operation of the car, such as turning off the ignition switch, pushing the driver out of the way, or blinding his view of the road by holding some object in front of his eyes. Of course, these acts would be breaches of the code section. But there are even more frequent acts constituting interference with the driver which are reprehensible, and the evidence on behalf of the plaintiff in the present action seems to present one of them. When the occupant of a back seat wilfully thrusts a baby forward into the front seat in such a way as to cause a lapse of the driver's control so that an accident will be caused and serious injuries inflicted, it is a dangerous and improper act which the code section in question forbids. The jury had a right to judge from all of the evidence in the case whether Mrs. Mangum wilfully and negligently interfered with the driver of the vehicle." (Id. at pp. 15-16.) On these facts, the Reclusado court held the trial court erred by granting a new trial on the defendants' behalf. (Id. at p. 16.)