 Beginning with the general policy-based proximate cause tests: the first of these are what we may call “ad hoc policy tests”. The idea is that courts balance a range of policies in each case that they adjudicate where a defendant has been found to have caused-in-fact a legally prohibited harm. They may balance certain “social interests”, like the need for deterrence, with certain “individual interests”, like the unfairness of surprising a defendant with liability (Edgerton 1924). Courts then decide wherever such balance leads. Whatever decision is reached on such case-by-case policy balancing is then cast in terms of “proximate” or “legal” cause. Such labels are simply the conclusions of policy balances; the labels have nothing to do with causation in any ordinary or scientific sense (Green 1929).