California, United States of America
The following excerpt is from Johnson v. Calvert, 19 Cal.Rptr.2d 494, 5 Cal.4th 84, 851 P.2d 776 (Cal. 1993):
The majority's resort to "but-for" causation is curious. The concept of "but-for" causation is a "test used in determining tort liability...." (Black's Law Dict. (6th ed. 1990) p. 200.) In California, the test for causation is whether the conduct was a "substantial factor" in bringing about the event. (Mitchell v. Gonzales (1991) 54 Cal.3d 1041, 1049, 1054, 1056 [disapproving[851 P.2d 796]
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