Polemis
"The fact that [the planks] did directly produce an unexpected result...does not relieve the person who was negligent from the damage which his negligent act directly caused."
The directness test: One is liable for any injury or damage directly caused by one's breach of duty.
Two problems with the directness test.
1. It is "too harsh a rule."
2. It leads "to nowhere but the never ending and insoluble problems of causation."
Instead: One is liable for reasonably foreseeable types of injury or damage.