 Most of Henry Edgerton’s much-cited work details his skepticism about proximate causation. Some of it, however, reveals him to have been a skeptic about the cause-in-fact requirement as well. He notes, for example, that the symmetrically concurrent overdetermination cases were divided into two camps by the cause-in-fact doctrines of his day: where there were two culpable actors starting fires (where the fires joined to produce a larger fire burning down the plaintiff’s house), either actor was a cause of the destruction; but when only one of the fires was of culpable origin, the other being either natural or of innocent human origin, then the culpable actor was not a cause of the destruction. From such examples, Edgerton suggested that the cause-in-fact requirement was (like the proximate cause requirement) all a matter of policy, a matter, that is, depending on “our free and independent sense of justice and—perhaps—the interests of society”.