Legal Commentary

In a couple hours, I'm going to be wrapping up some proximate cause materials in my criminal law class. Here's one thing I've been thinking about, and I would be curious to hear reactions to it.
Imagine the Kibbe case.  (K gets V snockered drunk, robs him, puts him in car, drives, and leaves V with pants at his ankles, without eyeglasses, on the side of an desolate night road in the cold.  V dies when struck in the middle of the lane by a driver who didn't see V.)

Now, imagine, as Dressler asks us, that instead of dying by a truck, a plane crashes in the road and kills V instead.  There you have foreseeable result (death of V) by unforeseeable manner (plane crash).

Should this manner of death by plane serve to break the chain of attributing proximate cause to Kibbe b/c  the unforeseeable manner is something Kibbe can't take precautions against? Recall the truck driving into V is something that can be more readily avoidable, in part because the truck impact is more foreseeable.  Should the law give an incentive to K to take care where K might otherwise not take care? Should we use a negligence rule or strict liability rule? 

It would seem to make sense to use a negligence rule, but consider:  s/l should induce optimal care and optimal activity levels, whereas a negligence rule will only induce optimal care.  So if we think the activity of placing people in danger by some foreseeable means should be eliminated, perhaps the s/l rule makes sense in terms of who's going to be the proximate cause. 

The main problem here is that I don't think any one person is thinking about proximate cause issues when committing their dangerous activities, so all this "magical thinking" is worth bupkis. On this view, it's hard to see why crim law theorists sometimes puzzle over doctrinal conundra like this apart from their inherent interest.  Is there a way to make sense of this to students? Should courts be moved by these considerations in advocacy?