number of other factors in Pennsylvania

30 Pennsylvania opinions name it 9 courts 1974–2025 4 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

Case	Followed	Cited
Wisniewski v. GREAT A. & P. TEA. CO.green pasuperct · 1974 · cited in 3 Pennsylvania opinions naming this issue, 1979–2005 2 sentences 2005Wisniewski, 226 Pa.Super. 574 , 323 A.2d 744, 748 (1974) (citing RESTATEMENT (SECOND) OF TORTS, § 431 (1965)). ¶ 17 The method for determining whether negligent conduct is a substantial factor in producing the injury is set forth in Willard v. Interpool, Ltd., 758 A.2d 684, 688 (Pa.Super.2000): The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they 2005Wisniewski, 226 Pa.Super. 574 , 323 A.2d 744, 748 (1974) (citing RESTATEMENT (SECOND) OF TORTS, § 431 (1965)). ¶ 17 The method for determining whether negligent conduct is a substantial factor in producing the injury is set forth in Willard v. Interpool, Ltd., 758 A.2d 684, 688 (Pa.Super.2000): The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they	2	3
Vattimo v. Lower Bucks Hospital, Inc.green pa · 1983 · cited in 2 Pennsylvania opinions naming this issue, 1994–2024 2 sentences 2024To determine proximate causation, a court should consider “(a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor’s conduct has created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon by other forces for which the actor is not responsible; (c) lapse of time.” Vattimo v. Lower Bucks Hosp., Inc., 465 A.2d 1231, 1234 (Pa. 1983) [(citing Restatement (Second) of Torts § 433 (1965)]. 1994Section 433 of the Restatement (Second) of Torts sets forth a method of determining whether negligent conduct is a substantial factor in producing the injury: The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor’s conduct has created a force or series of forces which are in continuous and active operati	2	2
Lux v. Gerald E. Ort Trucking, Inc.green pasuperct · 2005 · cited in 2 Pennsylvania opinions naming this issue, 2006–2020 2 sentences 2020Lux, supra at 1287 (citations omitted). -7- J-A03015-20 Flickinger v. Ritsky, 305 A.2d 40 (Pa. 1973) (adopting Restatement (Second) of Torts, § 447). 2006Ort Trucking, Inc., 887 A.2d 1281, 1286-1288 (Pa.Super.2005) (citations, brackets, and ellipses omitted), appeal denied, 587 Pa. 731 , 901 A.2d 499 (Pa.2006). ¶ 21 Appellant explains its theory of causation as follows: If C.F.	2	2
Betz v. Pneumo Abex LLCgreen pa · 2012 · cited in 2 Pennsylvania opinions naming this issue, 2018–2018 2 sentences 2018The section declares: The following considerations are in themselves or in combination with one another important in determining whether the actor's conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor's conduct has created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon by other forces for which the actor is not responsib 2018The section declares: The following considerations are in themselves or in combination with one another important in determining whether the actor's conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor's conduct has created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon by other forces for which the actor is not responsib	2	2
Willard v. Interpool, Ltd.green pasuperct · 2000 · cited in 2 Pennsylvania opinions naming this issue, 2005–2017 2 sentences 2017The method for determining whether negligent conduct is a substantial factor in producing the injury is set forth in Willard v. Interpool, Ltd., 758 A.2d 684, 688 (Pa. Super. 2000) [, appeal denied, 775 A.2d 808 (Pa. 2001)]: The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor’s conduct has created a fo 2005Wisniewski, 226 Pa.Super. 574 , 323 A.2d 744, 748 (1974) (citing RESTATEMENT (SECOND) OF TORTS, § 431 (1965)). ¶ 17 The method for determining whether negligent conduct is a substantial factor in producing the injury is set forth in Willard v. Interpool, Ltd., 758 A.2d 684, 688 (Pa.Super.2000): The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they	2	2
Martin v. Cincinnati Gas & Electric Co.green ca6 · 2009 · cited in 2 Pennsylvania opinions naming this issue, 2016–2016 2 sentences 2016Refractories Co., 95 S.W.3d 868, 873 (Ky. Ct. App. 2001); Martin, 561 F.3d at 443 (“[O]ne measure of whether an action is a substantial factor is the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it.”). 2016Refractories Co., 95 S.W.3d 868, 873 (Ky. Ct. App. 2001); Martin, 561 F.3d at 443 (“[0]ne measure of whether an action is a substantial factor is the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it.”).	2	2
Bailey v. North American Refractories Co.green kyctapp · 2003 · cited in 2 Pennsylvania opinions naming this issue, 2016–2016 2 sentences 2016Refractories Co., 95 S.W.3d 868, 873 (Ky. Ct. App. 2001); Martin, 561 F.3d at 443 (“[O]ne measure of whether an action is a substantial factor is the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it.”). 2016Refractories Co., 95 S.W.3d 868, 873 (Ky. Ct. App. 2001); Martin, 561 F.3d at 443 (“[0]ne measure of whether an action is a substantial factor is the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it.”).	2	2
Commonwealth ex rel. Martin v. Rundlegreen pa · 1967 · cited in 2 Pennsylvania opinions naming this issue, 1974–1974 2 sentences 1974Restatement (Second) of Torts §433 (1965); see Heck v. Beryllium Corp., 424 Pa. 140 , 226 A.2d 87 (1966) (section 433 of Restatement (Second) of Torts followed as to first consideration listed above). 1974Restatement (Second) of Torts § 433 (1965); see Heck v. Beryllium Corp., 424 Pa. 140 , 226 A.2d 87 (1966) (section 433 of Restatement (Second) of Torts followed as to first consideration listed above).	2	2
Heck v. Beryllium Corp.green pa · 1966 · cited in 2 Pennsylvania opinions naming this issue, 1974–1974 2 sentences 1974Restatement (Second) of Torts §433 (1965); see Heck v. Beryllium Corp., 424 Pa. 140 , 226 A.2d 87 (1966) (section 433 of Restatement (Second) of Torts followed as to first consideration listed above). 1974Restatement (Second) of Torts § 433 (1965); see Heck v. Beryllium Corp., 424 Pa. 140 , 226 A.2d 87 (1966) (section 433 of Restatement (Second) of Torts followed as to first consideration listed above).	2	2
Taylor v. Jacksongreen pacommwct · 1994 · cited in 3 Pennsylvania opinions naming this issue, 2005–2017 2 sentences 2005Section 433 of the Restatement (Second) of Torts sets forth a standard for determining whether negligent conduct is a substantial factor in producing the injury: “The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: “(a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; “(b) whether the actor’s conduct has created a force or series of forces which are in continuous and active o 2005Section 433 of the Restatement (Second) of Torts sets forth a standard for determining whether negligent conduct is a substantial factor in producing the injury: “The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: “(a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; “(b) whether the actor’s conduct has created a force or series of forces which are in continuous and active o	1	3
Ford v. Jeffriesgreen pa · 1977 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014 2 sentences 2014Pennsylvania has also adopted the definition of proximate cause set forth in the Restatement (Second) of Torts § 431 (1965), which reads, “The actor’s negligent conduct is a legal cause of harm to another if (a) his conduct is a substantial factor in bringing about the harm, and (b) there is no rule of law relieving the actor from liability because of the manner in which his negligence has resulted in the harm.” The Restatement (Second) of Torts § 433 establishes a tripartite tests for determining whether an actor’s conduct is a substantial factor in bring about harm to another. 1 The three re 2014Pennsylvania has also adopted the definition of proximate cause set forth in the Restatement (Second) of Torts § 431 (1965), which reads, “The actor’s negligent conduct is a legal cause of harm to another if (a) his conduct is a substantial factor in bringing about the harm, and (b) there is no rule of law relieving the actor from liability because of the manner in which his negligence has resulted in the harm.” The Restatement (Second) of Torts § 433 establishes a tripartite tests for determining whether an actor’s conduct is a substantial factor in bring about harm to another. 1 The three re	1	1
Holt v. NAVAPROgreen pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010 1 sentence 2010See Holt, supra at 921 .	1	1
Eckroth v. Pennsylvania Electric, Inc.green pasuperct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010 1 sentence 2010See Id.	1	1
Shafer v. State Employes' Retirement Boardgreen pa · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002 2 sentences 2002See Shafer v. State Employes’ Retirement Board, 548 Pa. 320 , 696 A.2d 1186 (1997). 2002See Shafer v. State Employes’ Retirement Board, 548 Pa. 320 , 696 A.2d 1186 (1997).	1	1
American Truck Leasing, Inc. v. Thorne Equipment Co.green pasuperct · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000 2 sentences 2000See American Truck Leasing, Inc. v. Thorne Equipment Co., 400 Pa.Super. 530 , 583 A.2d 1242, 1243 (1991), where we stated what constitutes a substantial factor as follows: The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor’s conduct has created a force or series of forces which are in continuous and a 2000See American Truck Leasing, Inc. v. Thorne Equipment Co., 400 Pa.Super. 530 , 583 A.2d 1242, 1243 (1991), where we stated what constitutes a substantial factor as follows: The following considerations are in themselves or in combination with one another important in determining whether the actor’s conduct is a substantial factor in bringing about harm to another: (a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; (b) whether the actor’s conduct has created a force or series of forces which are in continuous and a	1	1
Talarico v. Bonhamgreen pacommwct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999 2 sentences 1999Restatement (Second) of Torts §433; Talarico v. Bonham, 168 Pa. Commw. 467, 474-75 , 650 A.2d 1192, 1195-96 (1994). 1999Restatement (Second) of Torts §433; Talarico v. Bonham, 168 Pa. Commw. 467, 474-75 , 650 A.2d 1192, 1195-96 (1994).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (9)

Case	Cited	Years
Straw, J. v. Fair, K. v. Pittsburgh Lubes green pasuperct · 2018 2 sentences 2025Id. at 994-95 (quoting Restatement (Second) of Torts § 433) (quotation marks and subdivision markings omitted). 2023Factors relevant to the consideration of proximate cause include: “the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it”; “whether the actor's conduct has created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon by other forces for which the actor is not responsible; and the “lapse of time.” Id. at 994-95 (quoting Restatement (Second) of Torts § 433.) More than one cause may contribute to and thus proximately cause	3	2023–2025
Yee v. Roberts green pa · 2006 2 sentences 2014Lux at 1286-1288 (citations, brackets, and ellipses omitted), appeal denied, 587 Pa. 731 , 901 A.2d 499 (Pa.2006). 2006Ort Trucking, Inc., 887 A.2d 1281, 1286-1288 (Pa.Super.2005) (citations, brackets, and ellipses omitted), appeal denied, 587 Pa. 731 , 901 A.2d 499 (Pa.2006). ¶ 21 Appellant explains its theory of causation as follows: If C.F.	2	2006–2014
Grainy Ex Rel. Grainy v. Campbell green pa · 1981 1 sentence 2020The Court stated that, since 1973, the controlling law in Pennsylvania on “the extent of liability of a negligent actor, i.e., the law of proximate causation, where that question is presented in the light of an intervening act of negligence, is contained in section 447 of the Restatement (Second) of Torts (1965).” Id. at 381 , citing Estate of ____________________________________________ 3 The following considerations are of importance in evaluating whether negligent conduct is a substantial factor in producing an injury: (a) the number of other factors which contribute in producing the harm a	1	2020–2020
FLICKINGER ESTATE v. Ritsky green pa · 1973 1 sentence 2020Lux, supra at 1287 (citations omitted). -7- J-A03015-20 Flickinger v. Ritsky, 305 A.2d 40 (Pa. 1973) (adopting Restatement (Second) of Torts, § 447).	1	2020–2020
Feeney v. Disston Manor Personal Care Home, Inc. green pasuperct · 2004 1 sentence 2018"Two or more causes may contribute to and thus be the legal or proximate cause of an injury." Feen e y v. Disston Manor Personal Care Home, Inc. , 849 A.2d 590 , 595 (Pa. Super. 2004).	1	2018–2018
Hicks v. Metropolitan Edison Co. green pacommwct · 1995 1 sentence 2014Pennsylvania has also adopted the definition of proximate cause set forth in the Restatement (Second) of Torts § 431 (1965), which reads, “The actor’s negligent conduct is a legal cause of harm to another if (a) his conduct is a substantial factor in bringing about the harm, and (b) there is no rule of law relieving the actor from liability because of the manner in which his negligence has resulted in the harm.” The Restatement (Second) of Torts § 433 establishes a tripartite tests for determining whether an actor’s conduct is a substantial factor in bring about harm to another. 1 The three re	1	2014–2014
Equitable Gas Co. v. Pennsylvania Public Utility Commission green pacommwct · 1979 1 sentence 2011To the extent that the Commission mentioned the DSP Filings in its analysis on retroactive recovery, it did so only to point out that the Companies' filings are just "one data point that acknowledges Commission precedent with regard to these Companies and this issue.” (Order at 18.) We do not believe that this brief mention constitutes the Commission rendering a decision based on facts outside the record, Equitable Gas Company, 405 A.2d at 1059 , such that any error was harmless, particularly where the Commission relied upon a number of other factors which were supported by the record evidence	1	2011–2011
Brown v. Philadelphia College of Osteopathic Medicine green pasuperct · 2000 1 sentence 2007Thus, proximate cause “must be established before the question of actual cause may be put to the jury.” Reilly, supra. ¶ 16 The Restatement (Second) of Torts provides guidelines to determine whether a defendant’s conduct was the proximate cause of a plaintiffs injury: “(a) the number of other factors which contribute in producing the harm and the extent of the [ajffect which they have in producing it; (b) whether the actor’s conduct created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon	1	2007–2007
Foley v. Clark Equipment Co. green pa · 1987 2 sentences 1991In Pennsylvania, courts consider the following factors to determine whether the defective product is a substantial factor in the injury: “ ‘(a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; “ ‘(b) whether the actor’s conduct has created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon by other forces for which the actor is not responsible; “ ‘(c) lapse of time.’ Restatement (Second) of Torts §433.” Foley, 36 1991In Pennsylvania, courts consider the following factors to determine whether the defective product is a substantial factor in the injury: “ ‘(a) the number of other factors which contribute in producing the harm and the extent of the effect which they have in producing it; “ ‘(b) whether the actor’s conduct has created a force or series of forces which are in continuous and active operation up to the time of the harm, or has created a situation harmless unless acted upon by other forces for which the actor is not responsible; “ ‘(c) lapse of time.’ Restatement (Second) of Torts §433.” Foley, 36	1	1991–1991

Where else courts name it

PA 30 (1974–2025) MD 19 (1977–2025) CA 17 (1988–2023) IL 10 (1977–2024) TX 8 (1969–2024) OR 7 (1978–2018) TN 6 (1964–2019) WA 6 (1982–2020) MI 6 (1976–2025) AL 5 (1977–1982) NY 5 (1976–2019) IN 5 (2013–2020) WI 4 (1980–2017) IA 4 (2016–2018) CO 4 (1988–2026) NM 3 (1991–2025) DC 3 (1990–2010) MO 3 (1972–2001) OH 3 (2012–2024) MN 3 (1973–1987) ND 3 (1974–2002) AR 3 (1991–1997) CT 2 (1997–2010) SD 2 (1992–2008) WV 2 (2007–2021) LA 2 (1991–2009) GA 2 (2004–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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