What is the test for determining whether a defendant is a proximate cause of death in a civil case?

In People v. Vernon (1979) 89 Cal.App.3d 853, the court summarized the facts as follows: "The evidence shows [one defendant] participated in the beating of [the victim]. There was testimony by a witness that [that defendant], together with the others aforementioned, kicked [the victim] while he was on the ground. As the men, including [that defendant] kicked at the victim's prostrate body, the witness heard thuds as the kicks landed and heard [the victim] moan. Another witness also saw [that defendant], together with [the codefendant and two other men], kicking the victim." (Id. at p. 864.) Based on that evidence, the court concluded: "When the conduct of two or more persons contributes concurrently as proximate causes of death, the conduct of each person is a proximate cause regardless of the extent to which each contributes to the death." (Ibid.)

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"To establish . . . causal connection and for criminal liability to attach, the evidence must show that the defendant's conduct was both the actual and the legal, or proximate, cause of the . . . injuries" (People v. Marlin (2004) 124 Cal.App.4th 559, 569), meaning (1) " 'the defendant's conduct must be the "but-for" cause (sometimes called the "cause in fact") of the forbidden result' " (ibid.); and (2) " 'the defendant may fairly be held responsible for the actual result' " (ibid.). In other words, "the cause of the harm not only must be direct, but also [must] not [be] so remote as to fail to constitute the natural and probable consequence of the defendant's act." (People v. Roberts (1992) 2 Cal.4th 271, 319; see id. at p. 320, fn. 11 ["[T]here is no bright line demarcating a legally sufficient proximate cause from one that is too remote."].)