When do California courts deem a defendant to have “caused” personal injury to the extent that they should be held to pay damages to the injured party? This was a long standing debate in the State of California up until fairly recently. Based upon definitions of “causation” dating back to English tort law and moving forward to the 20th century, there were differing standards. In 1991, in a decision entitled Mitchell v. Gonzalez (1991) 54 Cal.3d 1091, the California Supreme Court made a ruling which did away with some of these varying definitions and made a decision that now forms the basis for the current jury instructions including California Civil Jury Instruction 430.