F: P had a verdict.
Fire caused by the negligence of the D, railway company, swept over a large area. It merged with another fire of independent and
I: When a fire joins with another and then causes the damage to the property, if either would have destroyed the property, whether the D is liable.
R: Where P is injured by the neg. conduct of more than one tortfeasor, each is independently liable if it was a substantial factor in bringing about P's injury
Co: independent concurrent causes
Here, not but for test is applied, rather substantial factor test (not but for test) is applied. some jurisdiction does this
In this case, negligence-nonnegligence test
Here, each of these two caused,
But that was missing in Ybbard case.