What is the test for determining whether a party is liable for an event that enables harm to occur?

An event that enables harm ultimately to occur need not necessarily be a substantial factor in bringing about the harm. [C]are must be taken to avoid confusing two elements which are separate and distinct, namely, that which causes the injury, and that without which the injury would not have happened. For the former the defendant may be liable, but for the latter he may not; that is to say, in order to make a defendant liable his wrongful act must be the causa causans [ (immediate cause) ], and not merely the causa sine qua non [ (necessary antecedent) ] [citation]. (Johnson v. Union Furniture Co. (1939) 31 Cal.App.2d 234, 237, 87 P.2d 917.) In a philosophical sense the causes of any accident or event go back to the birth of the parties and the discovery of America; but any attempt to impose responsibility upon such a basis would result in infinite liability, and would set society on edge and fill the courts with endless litigation. As a

[187 Cal.Rptr.3d 590]