 Consider first the well-known foreseeability test. Unlike the case with the rule-based policy tests, here there is no multiplicity of rules for specific situations (like long drawn out processes of death, intervening wrongdoers, railroad fires, etc.). Rather, there is one rule universally applicable to all criminal and tort cases: was it foreseeable to a defendant at the time that she acted that her act would cause the harm that it in fact caused? (Green 1967). This purportedly universal test for legal causation is usually justified by one of two policies: either the unfairness of punishing (or extracting compensation from) someone for harms that they could not foresee, or the inability to gain any deterrence by sanctioning such actors (since the threat value of tort or criminal law sanctions is commonly thought to be nonexistent for unforeseeable violations of liability rules).