As tort law developed after the Finney case, courts made distinctions between actual and proximate causes. A cause must be the actions of the defendant. The defendant’s actions can be considered an actual cause so long as the plaintiff’s injury would not have occurred but for the actions of the defendant, regardless of how fortuitous those actions were in relation to the injury. On the other hand, the defendant’s actions can be considered a proximate cause if those actions non-fortuitously led to the injury, i.e., the actions were an actual cause, plus, the actor should have known that the injury was a foreseeable outcome of his actions (pp. 209-210, 272).Goldberg, J. C. P., A. Sebok, B. Zipursky, 2004, Tort Law, Aspen, NY.