He meant to do that. Stunt pilots Lt. Ormer “Lock” Locklear and co-pilot Milton “Skeets” Elliot were filming The Skywayman, a silent movie released in 1920, and crashing the church steeple was part of the script.
From Wiki:
Principal photography on The Skywayman began on June 11, 1920, with DeMille Field 2 as the main base of operations. Despite Locklear’s public claim that new stunts “more daring ever filmed” would be involved, the production would rely heavily on models and less on actual stunt flying. Two stunts, a church steeple being toppled by Locklear’s aircraft and an aircraft-to-train transfer were both problematic and nearly ended in disaster.
Their final stunt did end in disaster, a nighttime dive that killed both Locklear and Elliot instantly when they didn’t pull up in time.
[Image found here.]
Tacky Raccoons 