How have courts determined who is responsible for what in a melee?

It is not unusual to have difficulty identifying who in a melee is responsible for what. In Perez v. City of Huntington Park (1992) 7 Cal.App.4th 817, the appellate court affirmed a judgment against a public entity even though the trial judge (acting as the trier of fact) was unable to determine which of four officers hit the plaintiff and ruled in favor of the individual defendants. The court stated, "Morally, [the city] should be liable to [plaintiff] in these circumstances. The procedural fact that [he] named and joined the employees (but was unable at trial to identify them) should not be controlling, in light of the substantive finding that two of [the city's] employees committed tortious acts." (Id. at pp. 821-822.)