Where a plaintiff claims psychiatric injury from a workplace incident but subsequent events (a separate physical injury and workplace conflict) provide an alternative explanation, and the plaintiff did not report symptoms linked to the original incident for 17 months, a trial judge is entitled to find that the original incident was not a material cause of the psychiatric condition. The possibility that the original incident rendered the plaintiff more vulnerable to subsequent events does not, without more, establish it as a material cause. The obiter discussion suggests that in rescue cases involving multiple potential tortfeasors, the burden of disentangling respective duties and breaches might fall on the defendants rather than the rescuer, though this was not decided.
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