California, United States of America
The following excerpt is from Lombardo v. Huysentruyt, 110 Cal.Rptr.2d 691, 91 Cal. App. 4th 656 (Cal. App. 2001):
One aspect of causation is cause in fact or actual cause: Was the defendant's conduct "a substantial factor in bringing about the injury." (Mitchell v. Gonzales (1991) 54 Cal.3d 1041, 1049.) The other is legal or proximate cause.
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