California, United States of America
The following excerpt is from Robins v. Kuhn, G043752, Super. Ct. No. 30-2008-00102173 (Cal. App. 2011):
But whether a defendant's conduct was a substantial factor is only one aspect of causation. "The other is legal or proximate cause." (Lombardo v. Huysentruyt (2001) 91 Cal.App.4th 656, 665-666.) "'"The doctrine of proximate cause limits liability; i.e., in certain situations where the defendant's conduct is an actual cause of the
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harm, he will nevertheless be absolved because of the manner in which the injury occurred.'" (Ibid.)
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