People v. Wilson 

Defendant was convicted of resisting a peace officer resulting in injury to the officer. Modified version of IPI jury instruction for resisting a police officer was an accurate statement of the law; it described the additional element that the State was required to prove as "That the defendant's act of resisting was a proximate cause of an injury to [the officer]." In the modified instruction, "the proximate cause" is not the same as "sole proximate cause." (HOLDRIDGE and McDADE, specially concurring.)