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C. CAUSATION240.CausationAn act [or omission] causes (injury/ otherdescription>) if the (injury/ other description>) is thedirect, natural, and probable consequence of the act [or omission] andthe (injury/ other description>) would not havehappened without the act [or omission]. A natural and probableconsequence is one that a reasonable person would know is likely tohappen if nothing unusual intervenes. In deciding whether a consequenceis natural and probable, consider all the circumstances established by theevidence. if multiple potential causes.>[There may be more than one cause of (injury/ other description>). An act [or omission] causes (injury/ other description>), only if it is a substantial factor in causing the(injury/ other description>). A substantial factor ismore than a trivial or remote factor. However, it does not have to be theonly factor that causes the (injury/ otherdescription>).]New January 2006; Revised February 2012, March 2024** Denotes changes only to bench notes and other commentaries.BENCH NOTESInstructional DutyIf causation is at issue, the court has a sua sponte duty to instruct on proximatecause. (People v. Bernhardt (1963) 222 Cal.App.2d 567, 590-591 [35 Cal.Rptr.401]; People v. Cervantes (2001) 26 Cal.4th 860, 866-874 [111 Cal.Rptr.2d 148, 29P.3d 225].) The committee has addressed causation in those instructions where theissue is most likely to arise. If the particular facts of the case raise a causation issueand other instructions do not adequately cover the point, give this instruction.If there is evidence of multiple potential causes, the court should also give thebracketed paragraph. (People v. Sanchez (2001) 26 Cal.4th 834, 845-849 [111Cal.Rptr.2d 129, 29 P.3d 209]; People v. Autry (1995) 37 Cal.App.4th 351, 363 [43Cal.Rptr.2d 135].)AUTHORITY• Proximate Cause. People v. Carney (2023) 14 Cal.5th 1130, 1137-1139, 1143[310 Cal.Rptr.3d 685, 532 P.3d 696]; People v. Cervantes, supra, 26 Cal.4th at61pp. 866-874; People v. Roberts (1992) 2 Cal.4th 271, 315-322 [6 Cal.Rptr.2d276, 826 P.2d 274].• Substantial Factor. People v. Sanchez, supra, 26 Cal.4th at pp. 845-849; Peoplev. Autry, supra, 37 Cal.App.4th at p. 363.• Independent Intervening Cause. People v. Cervantes, supra, 26 Cal.4th at pp.866-874.• Causation Instructions. People v. Sanchez, supra, 26 Cal.4th at pp. 845-849;People v. Roberts, supra, 2 Cal.4th at pp. 311-322; People v. Autry, supra, 37Cal.App.4th at p. 363.• Instructional Duty. People v. Bernhardt, supra, 222 Cal.App.2d at pp. 590-591.• “Natural and Probable Consequences” Defined. See People v. Prettyman (1996)14 Cal.4th 248, 291 [58 Cal.Rptr.2d 827, 926 P.2d 1013] (conc. & dis. opn. ofBrown, J.).• Act or Omission. People v. Cervantes, supra, 26 Cal.4th at p. 866.SECONDARY

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District Court certified the case as a class action, with a class including "all persons who qualify for legalization but who were deemed ineligible for legalization under the original [reentry] policy, who learned of their ineligibility following promulgation of the policy and who, relying upon information that they were ineligible, did not apply for legalization before the May 4, 1988 deadline." No. 87-4757-WDK (JRx) (CD Cal., July 15, 1988) (App. 216). The LULAC plaintiffs also challenged the modified policy, claiming that aliens should not have to comply with the requirement of 8 C.F.R. § 245a.2(b)(10) (1992) to obtain a waiver of excludability for having fraudulently procured entry into the United States. With respect to this challenge, the District Court certified a second class comprising persons adversely affected by the modified policy. See No. 87-4757-WDK (JRx) (CD Cal., July 15, 1988) (App. 216). However, the District Court ultimately rejected the challenge to the modified policy, see ibid. (App. 234), and the LULAC plaintiffs did not appeal the grant of summary judgment to the INS on this issue. On July 15, 1988, 10 weeks after the end of the 12-month application period, the District Court held the regulation invalid, while reserving the question of remedy. Ibid. (App. 224-225). Again, the INS took no appeal. The LULAC plaintiffs then sought a remedial order extending the application period for class members to November 30, 1988, and compelling the INS to publicize the modified policy and the extended application period. They argued that the INS had effectively truncated the 12-month application period by enforcing the invalid regulation, by publicizing the regulation so as to dissuade potential applicants, and by failing to give sufficient publicity to its change in policy. On August 12, 1988, the District Court granted the plaintiffs' request for injunctive relief. No. 87-4757-WDK (JRx) (CD Cal., Aug. 12, 1988) (App. to Pet. for Cert. 50a). The INS appealed this remedial order. As in the CSS case, this date was chosen to coincide with the deadline for legalization applications under the Reform Act's SAW program. No. 87-4757-WDK (JRx) (CD Cal., Aug. 12, 1988) (App. to Pet. for Cert. 50a); see n. 5, supra. The order also required the INS to give those illegal aliens apprehended by INS enforcement officials "adequate time" to apply for legalization. App. to Pet. for Cert. 60a; see n. 2, supra, (describing the Act's provisions regarding such aliens); n. 6,

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No sua sponte duty to define the terms “possession,” “fear,” and “immediatepresence.” (People v. Anderson (1966) 64 Cal.2d 633, 639 [51 Cal.Rptr. 238, 414P.2d 366] [fear]; People v. Mungia (1991) 234 Cal.App.3d 1703, 1708 [286Cal.Rptr. 394] [fear].) These definitions are discussed in the Commentary below.If second degree robbery is the only possible degree of robbery that the jury mayreturn as their verdict, do not give CALCRIM No. 1602, Robbery: Degrees.Give the bracketed definition of “against a person’s will” on request.If there is an issue as to whether the defendant used force or fear during thecommission of the robbery, the court may need to instruct on this point. (See Peoplev. Estes (1983) 147 Cal.App.3d 23, 28 [194 Cal.Rptr. 909].) See CALCRIM No.3261, While Committing a Felony: Defined - Escape Rule.AUTHORITY• Elements. Pen. Code, § 211.CALCRIM No. 1600 ROBBERY AND CARJACKING1110• Fear Defined. Pen. Code, § 212; see People v. Collins (2021) 65 Cal.App.5th333, 340-341 [279 Cal.Rptr.3d 407]; People v. Cuevas (2001) 89 Cal.App.4th689, 698 [107 Cal.Rptr.2d 529] [victim must actually be afraid].• Immediate Presence Defined. People v. Hayes (1990) 52 Cal.3d 577, 626-627[276 Cal.Rptr. 874, 802 P.2d 376].• Intent. People v. Green (1980) 27 Cal.3d 1, 52-53 [164 Cal.Rptr. 1, 609 P.2d468], overruled on other grounds in People v. Hall (1986) 41 Cal.3d 826, 834,fn. 3 [226 Cal.Rptr. 112, 718 P.2d 99]; see Rodriguez v. Superior Court (1984)159 Cal.App.3d 821, 826 [205 Cal.Rptr. 750] [same intent as theft].• Intent to Deprive Owner of Main Value. See People v. Avery (2002) 27 Cal.4th49, 57-58 [115 Cal.Rptr.2d 403, 38 P.3d 1] [in context of theft]; People v.Zangari (2001) 89 Cal.App.4th 1436, 1447 [108 Cal.Rptr.2d 250] [same].• Possession Defined. People v. Bekele (1995) 33 Cal.App.4th 1457, 1461 [39Cal.Rptr.2d 797], disapproved on other grounds in People v. Rodriguez (1999)20 Cal.4th 1, 13-14 [82 Cal.Rptr.2d 413, 971 P.2d 618].• Robbery of Store Employee or Contractor. People v. Frazer (2003) 106Cal.App.4th 1105, 1115-1117 [131 Cal.Rptr.2d 319]; People v. Gilbeaux (2003)111 Cal.App.4th 515, 521-522 [3 Cal.Rptr.3d 835].• Constructive Possession by Employee. People v. Scott (2009) 45 Cal.4th 743,751 [89 Cal.Rptr.3d 213, 200 P.3d 837].• Constructive Possession by Subcontractor/Janitor. People v. Gilbeaux (2003) 111Cal.App.4th 515, 523 [3 Cal.Rptr.3d 835].• Constructive Possession by Person With Special Relationship. People v. Weddles(2010) 184 Cal.App.4th 1365, 1369-1370 [109 Cal.Rptr.3d 479].• Felonious Taking Not Satisfied by Theft by False Pretense. People v. Williams(2013) 57 Cal.4th 776, 784-789 [161 Cal.Rptr.3d 81, 305 P.3d 1241].• Constructive Possession and Immediate Presence of Funds in Account ofRobbery Victims Using ATM. People v. Mullins (2018) 19 Cal.App.5th 594, 603[228 Cal.Rptr.3d 198].COMMENTARYThe instruction includes definitions of “possession,” “fear,” and “immediatepresence” because those terms have meanings in the context of robbery that aretechnical and may not be readily apparent to jurors. (See People v. McElheny (1982)137 Cal.App.3d 396, 403 [187 Cal.Rptr. 39]; People v. Pitmon (1985) 170Cal.App.3d 38, 52 [216 Cal.Rptr. 221].)Possession was defined in the instruction because either actual or constructivepossession of property will satisfy this element, and this definition may not bereadily apparent to jurors. (People v. Bekele (1995)