 Such a mechanistic conception of causation is mostly a suggestion in the legal literature because of the elusive and seemingly mysterious use of “energy” and “force” by legal theorists (Hart &amp; Honoré 1959). One suspects that some such view is often applied by jurors, but unless theorists can spell out the general nature of the relation being intuitively applied by jurors, this test tends to collapse to the metaphysically sparer (because primitivist) substantial factor test.