Proximate Cause

Proximate Cause (legal cause): a normative limit on actual cause. Even where but-for is satisfied, ∆ is not liable if the result is too remote, attenuated, or accidental.

Doctrine

The chain of causation may be broken by a superseding intervening cause.
- Dependent intervening cause (responsive to ∆'s act): does NOT break the chain.
  - Examples: medical malpractice after a wounding; victim's foreseeable self-protective response; victim's flight from attack.
- Independent intervening cause (free, deliberate, informed third-party act, or freak natural event): DOES break the chain.
  - Examples: lightning strike on the gurney; victim's deliberate, unforeseeable decision to do something unrelated.
Test: was the intervening cause foreseeable? If yes, ∆ remains the proximate cause.

MPC § 2.03(2)

Liability lies unless the actual result "is too remote or accidental in its occurrence to have a just bearing on the actor's liability or on the gravity of his offense."
More flexible than CL: focuses on culpability rather than mechanical foreseeability.

Why Proximate Cause Matters

Without it, but-for liability would extend infinitely (e.g., A hits B; B is taken to hospital; ambulance crashes; B dies → A is "the cause"). Proximate cause cuts this off.

Cases:

Stephenson v. State, 179 N.E. 633 (Ind. 1932) — victim's suicide foreseeable; ∆ remains proximate cause.
People v. Acosta, 284 Cal. Rptr. 117 (Cal. Ct. App. 1991) — high-speed chase; helicopter collision foreseeable.
State v. McGee — medical treatment as dependent intervening cause.

See Actual Cause for the cause-in-fact step.