is preeminently concerned with culpability, rather than actual causation. The "Risk Rule" Referred to by the Reporters of the Second and Third Restatements of the Law of Torts as the "scope-of-the-risk" test, the term "Risk Rule" was coined by the University of Texas School of Law's Dean Robert Keeton. The rule is that “[a]n actor’s liability is limited to those physical harms that result from the risks that made the actor’s conduct tortious.” Thus, the operative question is "what were the particular risks that made an actor's conduct negligent?" If the injury suffered is not the result of one of those risks, there can be no recovery. Two examples will illustrate this principle: The classic example is that of a father who gives his child a loaded gun, which she carelessly drops upon the plaintiff's foot, causing injury. The plaintiff argues that it is negligent to give a child a loaded gun and that such negligence caused the injury, but this argument fails, for the injury did not result from the risk that made the conduct negligent. The risk that made the conduct negligent was the risk of the child accidentally firing the gun; the harm suffered could just as easily have resulted from handing the child an unloaded gun. Another example familiar to law students is that of the restaurant owner who stores rat poison above the grill in his luncheonette. The story is that during the lunch rush, the can explodes, severely injuring the chef who is preparing food in the kitchen. The chef sues the owner for negligence. The chef may not recover. Storing rat poison above the grill was negligent because it involved the risk that the chef might inadvertently mistake it for a spice and use it as an ingredient in a recipe. The explosion of the container and subsequent injury to the chef was not what made the chosen storage space risky. The notion is that it must be the risk associated with the negligence of the conduct that results in an injury, not some other risk invited by aspects of the conduct that in of themselves would not be negligent. Controversy The doctrine of proximate cause is notoriously confusing. The doctrine is phrased in the language of causation, but in most of the cases in which proximate cause is actively litigated, there is not much real dispute that the defendant but-for caused the