in deciding if d caused the ... to V there are 2 tests, Firstly factual causation is used to decide if but for the D guilty act, White. But for... doing .. wouldn't have occurred.
Second legal causation needs to be satisfied, D needs to be the substantial and operating cause of ..., however they do not need to be the only cause
Substantial cause requires the ds role to be more than minimal in Kimsey, this was said to be more than a slight of trifling link ( apply)