I respectfully dissent.
The narrow question presented in this case, which comes to us on summary judgment, is whether defendants have demonstrated, with respect to the proximate cause element of plaintiff’s claim, that “there is no triable issue as to any material fact and that [defendants are] entitled to a judgment as a matter of law.” (Code Civ. Proc., § 437c, subd. (c).) The majority clouds the issue with repeated references to Sharon P. v. Arman, Ltd. (1999) 21 Cal.4th 1181 [91 Cal.Rptr.2d 35, 989 P.2d 121] (Sharon P.) and Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666 [25 Cal.Rptr.2d 137, 863 P.2d 207] (Ann M), cases in which we were concerned with policy-laden questions about the existence and scope of a landlord’s duty to maintain reasonably safe premises. There, we articulated limitations on such duties, thus providing California property owners with significant protection against potential premises liability. But defendants in this case do not contest the trial court’s finding—based on overwhelming evidence—that they owed and breached a duty of care toward plaintiff.
The majority thus mistakenly identifies our primary concern in this case as “the need to balance . . . competing policy concerns” (maj. opn., ante, at p. 766). The question of causation long has been recognized as a factual one, and it is only “ ‘where reasonable men [and women] will not dispute the absence of causality’ ” (Constance B. v. State of California (1986) 178 Cal.App.3d 200, 207 [223 Cal.Rptr. 645]) that it becomes a question of law and may properly be withheld from the jury. Our prior pronouncements specifically recognize that causation is a question of fact in this type of case, i.e., where the issue is whether the defendant’s negligence was a substantial factor in causing injuries inflicted during a criminal attack by a third party. (See, e.g., Landeros v. Flood (1976) 17 Cal.3d 399, 411 [131 Cal.Rptr. 69, 551 P.2d 389, 97 A.L.R.3d 324].)
In its recent premises liability jurisprudence—including Sharon P. (landlord has no duty to secure premises absent “indications of a reasonably foreseeable risk of violent criminal assaults in that location” [21 Cal.4th at p. 1199; see also id. at p. 1200 (cone. & dis. opn. of Werdegar, J.)]) and Ann M. (a “high degree of foreseeability” of similar assaults is required to impose duty of hiring security guards [6 Cal.4th at p. 679])—this court has gone far to protect California landlords; the majority, in my view, goes astray in this case in straining further to insulate even the most careless from their minimal responsibilities and, in so doing, distorts the law of causation.
Contrary to the majority’s implication, were this case permitted to proceed it would not go to the jury on “ ‘abstract negligence [alone]’ ” (maj. opn., *786ante, at p. 773), nor, emphatically, would allowing trial on causation “ ‘make the landowner the insurer of the absolute safety of everyone who enters the premises’ ” (id. at p. 774). Plaintiff’s causation evidence, including her own testimony and that of her expert, is both detailed and nonspeculative. And affirmance on plaintiff’s causation theory would vindicate nothing more than the established principle that, “[w]here the occupier of land is aware of a concealed condition involving in the absence of precautions an unreasonable risk of harm to those coming in contact with it . . . , the trier of fact can reasonably conclude that a failure to warn or to repair the condition constitutes negligence.” (Rowland v. Christian (1968) 69 Cal.2d 108, 119 [70 Cal.Rptr. 97, 443 P.2d 561, 32 A.L.R.3d 496].)
We do not in this case confront a difficult line-drawing problem. (See maj. opn., ante, at p. Ill, wondering “ ‘[h]ow many guards are enough? Ten? Twenty? Two hundred?’ ”) Defendants failed to provide any regular daytime security personnel—except, significantly, for their own manager. Had defendants’ guard, charged with escorting their manager, escorted plaintiff, it is difficult to imagine that the attack on plaintiff would have occurred. And, to the extent providing a single guard charged with escorting daytime deliveries might have discharged defendants’ obligation to plaintiff, that is all we need to say. Obviously, what constitutes reasonable care in a future case remains a factual question dependent on the circumstances.
It bears emphasis that if a defendant has taken reasonable care in the discharge of its duty, then no breach will be found even if a plaintiff nevertheless suffers injury. Our permitting this case to proceed, therefore, would not make a landlord the “insurer” of all who enter its premises. In suggesting otherwise, the majority engages in an emotional argument devoid of legal analysis.
The majority concludes in essence that defendants met their burden of showing that the proximate cause element of plaintiff’s claim “cannot be established” (Code Civ. Proc., § 437c, subd. (o)(2)) by pointing to the probabilistic nature of her evidence, particularly her expert’s declaration. Because “she cannot prove the identity or background of her assailants” (maj. opn., ante, at p. 776), the majority reasons, she cannot show that defendants’ lax daytime security was a substantial factor in causing her injuries. (Ibid., citing, inter alia, Nola M. v. University of Southern California (1993) 16 Cal.App.4th 421 [20 Cal.Rptr.2d 97] (Nola M.); Leslie G. v. Perry & Associates (1996) 43 Cal.App.4th 472 [50 Cal.Rptr.2d 785] (Leslie G.).) For the following reasons, I disagree.
First, the majority’s argument depends on false premises. It is not plaintiff’s position that defendants were negligent in failing to post guards at the *787complex gates in particular. Rather, she alleges in her complaint that defendants “failed to maintain their premises in a safe condition and failed to provide adequate security to persons on their property.” Her expert testified that “daytime security [guards] and a more concerted effort to keep the gates repaired and closed” (italics added) would have deterred the attack she suffered. The majority mischaracterizes plaintiff’s position apparently because it wishes to argue “she cannot show that defendants’ failure to provide increased daytime security at each entrance gate or functioning locked gates was a substantial factor in causing her injuries” (maj. opn., ante, at p. 776), but the argument is a non sequitur. Plaintiff does not have to prove that security lapses “at each entrance gate” contributed to her injuries; she has only to raise a triable issue as to whether she would have been attacked “if defendants had provided [reasonable] additional security precautions” (id. at p. 767).
The majority also relies on the patently false assumption that “[t]he primary reason for having . . . guards stationed at every entrance would be to exclude unauthorized persons and trespassers from entering.” (Maj. opn., ante, at p. 776.) To the contrary, I submit, it is plain that defendants’ primary reason (as ordinarily it would be any landlord’s primary reason) for having security guards was to deter all criminal behavior, not just trespassing, by any person (including tenants, not just unauthorized entrants).
As the majority concedes, defendants’ ongoing (day and night) crime problem included criminal activity throughout the premises by tenants and their guests, including possible gang members. (See maj. opn., ante, at p. 770.) The security guards defendants engaged for night duty were charged with patrolling and protecting—and routinely did patrol—the entire premises. Numerous patrol officers’ reports, submitted by both sides, reveal that defendants’ guards secured and monitored vacant apartments, parking lots, carports and parked vehicles, swimming pool areas, a weight room, a storage shed, laundry rooms, and trash bin areas. Indeed, references to “continuous patrol of the complex” appear in almost every patrol report in the record. These same reports reveal that defendants’ nighttime security guards regularly approached and were approached by tenants and their guests, in the common areas and at tenants’ front doors, in connection with suspected criminal activity, such as vandalism, car theft, drug activity, and noise. Dozens of patrol reports note that security guards “checked for any suspicious activity” throughout the complex. Such evidence renders incredible the majority’s pretense that defendants’ nighttime security guards were—and that, impliedly, any daytime security guards would likewise have been— “stationed at every entrance” primarily to “exclude . . . trespassers.” (Maj. opn., ante, at p. 776.)
*788The majority adopts this false premise, again, apparently because it wishes to argue that “the assault on plaintiff could well have been made by tenants having authority to enter and remain on the premises.” (Maj. opn., ante, at p. 776.) As plaintiff “cannot prove the identity or background of her assailants” {ibid.), the majority argues, she has an insurmountable proof problem. But this argument also is a non sequitur, because plaintiff does not have to prove she was assaulted by a nontenant. She has only to raise a triable issue as to whether defendants’ failure to provide increased daytime security was a “substantial factor” in causing her injuries. (Mitchell v. Gonzales (1991) 54 Cal.3d 1041, 1052-1054 [1 Cal.Rptr.2d 913, 819 P.2d 872]; see also Rest.2d Torts, § 431, subd. (a).)
Second, the majority’s attack on plaintiff’s causation evidence is specious. The majority seeks to invoke the rule that “ ‘proof of causation cannot be based on ... an expert’s opinion based on inferences, speculation and conjecture.’ ” (Maj. opn., ante, at p. 775, quoting Leslie G., supra, 43 Cal.App.4th at p. 488.) But the majority’s attempt is unavailing, as the rule does not apply.
Plaintiff’s causation evidence is not suspect merely because it includes expert testimony. The cases are legion in which expert testimony is accepted as competent evidence of causation.1 The majority never makes clear whether its global attack on “the speculative testimony of supposed security ‘experts’ ” (maj. opn., ante, at p. 774) is meant to overrule such cases.
Nor is plaintiff’s causation evidence “ ‘pure speculation or conjecture’ ” (maj. opn., ante, at p. 776) because some of it is probabilistic. “ ‘Proof of the relation of cause and effect can never be more than “the projection of our habit of expecting certain consequents to follow certain antecedents merely because we have observed those sequences on previous occasions.” When a *789child is drowned in a swimming pool, no one can say with certainty that a lifeguard would have saved him; but the experience of the community is that with guards present people are commonly saved, and this affords a sufficient basis for the conclusion that it is more likely than not that the absence of the guard played a significant part in the drowning. Such questions are peculiarly for the jury. Whether proper construction of a building would have withstood an earthquake, whether reasonable police precautions would have prevented a boy from shooting the plaintiff in the eye with an airgun, whether a broken flange would have made an electric car leave the rails in the absence of excessive speed, whether a collision would have occurred if the defendant had not partially obstructed the highway, and many similar questions, cannot be decided as a matter of law.’ ” (Campbell v. General Motors Corp., supra, 32 Cal.3d at p. 120, quoting Prosser, Proximate Cause in California (1950) 38 Cal. L.Rev. 369, 382-383, italics added in Campbell.)
Similarly, no one can say with certainty that heightened security would have deterred the attempted rape of plaintiff, nor is this plaintiff’s burden. Contrary to the majority’s implication, plaintiff is not required to show that “roving guards” or any particular security measure or combination of security measures “would have . . . prevented the attack.” (Maj. opn., ante, at p. Ill, italics added.) The experience of the community is that with security guards present such crimes commonly are deterred. “The fact of causation is incapable of mathematical proof, since no man can say with absolute certainty what would have occurred if the defendant had acted otherwise. If, as a matter of ordinary experience, a particular act or omission might be expected to produce a particular result, and if that result has in fact followed, the conclusion may be justified that the causal relation exists.” (Rest.2d Torts, § 433B, com. b, p. 443.) To the extent the majority holds otherwise, it effects a monumental alteration of tort law without explanation or justification.
The mere fact expert testimony is comprised partly of opinion does not render it speculative. (See Juchert v. California Water Service Co. (1940) 16 Cal.2d 500, 507 [106 P.2d 886] [a party’s “ ‘ “ ‘suggestion of theories’ ” ’ ” on causation “ ‘ “ ‘does not reduce the jury to mere speculation, and disqualify it from determining the cause of the injury complained of’ ” ’ ”].) The majority attacks plaintiff’s expert’s opinion—viz., that the “attempted rape on the plaintiff would not have occurred had there been daytime security”—as “speculative” on the ground “assaults and other crimes can occur despite the maintenance of the highest level of security.” (Maj. opn., ante, at p. 111.) The attack fails because the truism that no security system can foreclose every possibility of crime does not entail, as the majority implies, that no causal inferences can ever be based on an evaluation of particular *790security arrangements. If required to foreclose the logical possibility that a seeming causal link is only that, absent confirming testimony by the culprit, no plaintiff could ever prove causation, yet such is what the majority impliedly would require of plaintiff here. (See maj. opn., ante, at p. 775 [invoking Leslie G.’s rejection of expert testimony on the ground “ ‘there is evidence that the assault could have occurred even in the absence of the landlord’s negligence’ ”].)
Third, the majority flatly misstates the requirements for proof of causation. California’s “substantial factor [causation] standard is a relatively broad one, requiring only that the contribution of the individual cause be more than negligible or theoretical.” (Rutherford v. Owens-Illinois, Inc. (1997) 16 Cal.4th 953, 978 [67 Cal.Rptr.2d 16, 941 P.2d 1203].) The majority misunderstands the substantial factor test, improperly suggesting it burdens plaintiff with proving it “ ‘more probable than not’ ” (maj. opn., ante, at p. 776) that defendants’ carelessness caused her injuries.
Moreover, in requiring plaintiff to “prove [her assailants] would not have succeeded in assaulting her if defendants had provided additional security precautions” (maj. opn., ante, at p. 767), the majority both misstates the applicable proof burden and places it on the wrong party. Plaintiff need only raise “a triable issue” of fact. (Code Civ. Proc., § 437c, subd. (o)(2).) “The issue of causation may be decided as a question of law only if, under undisputed facts, there is no room for a reasonable difference of opinion.” (Kurinij v. Hanna & Morton (1997) 55 Cal.App.4th 853, 864 [64 Cal.Rptr.2d 324]; accord, Pool v. City of Oakland (1986) 42 Cal.3d 1051, 1063 [232 Cal.Rptr. 528, 728 P.2d 1163].) And at the summary judgment stage, it is the defendant that has the burden of showing “that one or more elements of the cause of action . . . cannot be established.” (Code Civ. Proc., § 437c, subd. (o)(2).)2 In failing to come to grips with these rudimentary aspects of a lawsuit sounding in tort, the majority ignores standard procedure and calls into question a body of law long thought settled.
Contrary to the majority’s suggestion, we do not require that tort plaintiffs, in order to evade summary judgment, “show some substantial link or nexus between omission and injury” (maj. opn., ante, at p. 778) beyond what “a rule of common sense” (ibid.) as applied by a reasonable jury might reveal. Like other fact questions, that of causation indisputably is entrusted *791to “the common sense which we have traditionally attributed to that body.” (O’Keefe v. South End Rowing Club (1966) 64 Cal.2d 729, 755 [51 Cal.Rptr. 534, 414 P.2d 830, 16 A.L.R.3d 1] (dis. opn. of Peek, J.).) In the past, we have found “no reason to assume that a . . . common sense determination of . . . [causal] responsibility will be beyond the ken of . . . juries” (Safeway Stores, Inc. v. Nest-Kart (1978) 21 Cal.3d 322, 332 [146 Cal.Rptr. 550, 579 P.2d 441]), and the majority provides no reason to assume so here.
As noted, the majority speculates “the assault on plaintiff could well have been made by tenants” (maj. opn., ante, at p. 776), but even if accurate that surmise is not determinative. Indeed, the possibility of criminal assaults by tenants would point to the need for heightened daytime security. That tenants by definition are “authorized and empowered to enter . . . and remain on the premises” (ibid.) obviously cannot diminish—or, as the majority effectively would have it, eliminate—a landlord’s duty to “maintain their premises in a reasonably safe condition” (Sharon P., supra, 21 Cal.4th at p. 1189), which duty, in any event, defendants do not dispute. That plaintiff cannot eliminate tenants as the culprits cannot fulfill defendants’ “burden of showing that a cause of action has no merit” (Code Civ. Proc., § 437c, subd. (o)(2)).
Defendants, it bears repeating, do not dispute they had a duty to plaintiff, that they breached that duty, and that plaintiff sustained serious injuries. At a minimum, reasonable minds can differ as to the inferences to be drawn from the causation evidence plaintiff has adduced, i.e., as to whether the haven for crime defendants knowingly allowed to flourish at their apartment complex was a substantial factor contributing to the attack on plaintiff. The majority cites no rule of law that would bar a jury’s drawing an inference either way.
The majority’s core authorities on the causation question are neither binding nor persuasive. Nola M., supra, 16 Cal.App.4th 421, and Leslie G., supra, 43 Cal.App.4th 472, on which the majority principally relies, being Court of Appeal opinions, do not bind this court. Nola M., in fact, conflicts with our prior pronouncements. (Compare Isaacs v. Huntington Memorial Hospital (1985) 38 Cal.3d 112, 131, fn. 8 [211 Cal.Rptr. 356, 695 P.2d 653] (Isaacs) [implying that foreseeability evidence considered by trial court in ruling on duty could raise triable causation issue] with Nola M., supra, at p. 428, fn. 5 [dismissing our footnote in Isaacs as a “slip of the pen”].) The majority does not expressly disavow our implication in Isaacs, but purports to distinguish this case as involving only “a general finding of . . . foreseeability” that “criminal assaults of some kind might occur on the premises.” (Maj. opn., ante, at pp. 777, 778; see also p. 777, citing Isaacs, supra, at p. 131, fn. 8.) Contrary to the majority’s characterization, the trial court’s *792minute order on summary judgment, noting “overwhelming evidence” of “rampant violence” in the complex, expressly finds a “ ‘high foreseeability’ that violent crime would occur on [defendants’] premises” (italics added). (Cf. Ann M., supra, 6 Cal.4th at p. 679 [high degree of foreseeability permits finding that “the scope of a landlord’s duty of care includes the hiring of security guards”].)
In any event, Ñola M. and Leslie G. are readily distinguishable. Ñola M., supra, involved only marginal misfeasance (see 16 Cal.App.4th at p. 425 [defendant university provided eight trained security officers for patrolling quarter-mile-square area]), rather than, as here, complete nonfeasance, defendants having provided no daytime security whatsoever. Leslie G., supra, involved a rape perpetrated by a single person in an underground parking garage in the middle of the night (43 Cal.App.4th at pp. 476-477), whereas the attack here was perpetrated by three men in broad daylight in a walkpath across defendants’ premises. Indisputably, a reasonable jury in this case could conclude, contrary to the majority, that “roving guards would have encountered [plaintiff’s] assailants or prevented the attack” (maj. opn., ante, at p. 777). Certainly, at the least, a jury could reasonably infer that an escort would have done so. Ultimately, the majority cites no authority either compelling or justifying its foreclosure of plaintiff’s opportunity to seek relief for the grievous injuries she sustained while delivering a package on defendants’ premises.
Viewed objectively, plaintiff’s causation evidence plainly raises a triable issue of fact. The record reveals that plaintiff presented, aside from her expert’s declaration, considerable direct, nonspeculative evidence on causation. She testified to the circumstances of the assault as follows: She was attacked on a clear, sunny day and was carrying a package at the time. She first saw two of the attackers loitering outside a propped-open gate as she entered the complex, and first saw the third when she was walking through the complex to deliver the package. The apartment to which she tried to deliver her package was on the ground floor, and before going there she consulted some sort of “central map.” She waited about two minutes for the doorbell to be answered; when it was not, she chose one of the straighter (less “winding”) exit walkways, which headed towards an exit on the south side of the complex.
The parties’ separate statements of undisputed facts establish that the assault on plaintiff took place while she was in the walkpath. Plaintiff testified that she stopped and looked at her assailants before they jumped her, that her assailants engaged her in conversation before they physically attacked her, and that what they said to her panicked her.
*793The record also contains the declaration of plaintiff’s expert, Robert Feliciano. Feliciano inspected the premises, interviewed plaintiff about the attack, and reviewed records showing what security was in place at the time of the attack. Feliciano also reviewed depositions given by defendants’ head of security and defendants’ on-site manager. He reviewed police records showing that a massive, ongoing crime problem existed at the premises, as well as private security records revealing that drug trafficking occurred on the premises the day of the attack and describing the general state of security on the premises in the period preceding the attack on plaintiff.
Feliciano further was informed that local police had advised defendants to hire daytime security guards and was apprised of defendants’ manager’s standing request for a security escort whenever she proceeded from her apartment to her vehicle, which request was in place the day plaintiff was attacked. Contrary to the majority’s implication, therefore, Feliciano delivered, not an opinion “resting solely on speculation and surmise” (maj. opn., ante, at p. 775), but an opinion based on direct evidence from several sources about conditions on the day of the attack, the location of the attack, the movements of the persons involved, and details of the attack itself. The majority does not dispute that plaintiff’s expert was qualified to opine on the efficacy of security guards to deter particular types of crimes under particular circumstances. (See maj. opn., ante, at p. 771.) Unquestionably, the evidence on which he relied was sufficient rationally to ground his testimony that plaintiff’s injuries probably would not have occurred if defendants hád supplied daytime security.
In sum, plaintiff submitted sufficient evidence, including expert testimony, to permit a rational jury to find that defendants’ omissions were a substantial factor in causing her injuries. As explained, plaintiff’s testimony included details about the perpetrators, the location, the circumstances and the events of the attack she suffered. A rational jury hearing plaintiff’s testimony alone could find it probable that reasonable daytime security patrols, or an on-call security escort for delivery people (like the one defendants engaged for their manager), would have deterred her attackers. And a rational jury certainly could find a causal link credibly established by the combination of plaintiff’s testimony and her expert’s declaration, which drew on a variety of disinterested sources. To this we must add plaintiff’s evidence that a county sheriff who had “worked closely with the premises during the period of the attack and one year prior to the attack” told defendants they should “hire more security during the daytime.” A rational jury certainly could conclude police would not have given such advice unless they believed daytime security would have diminished crime at the *794complex. Evidently defendants themselves believed in the efficacy of security guards or they would not have engaged them, as they did at night and to escort their manager. The majority does not even attempt to justify its casual rejection of this weighty evidence.
The majority mischaracterizes plaintiff’s causation theory as depending on the notion that “her assailants were indeed unauthorized to enter” (maj. opn., ante, at p. 776) and, warping both causation and evidence law, requires her to “prove the identity or background of her assailants” (ibid..). The majority fails even to acknowledge, let alone evaluate, the detailed and specific evidence plaintiff presented regarding the perpetrators, location, and circumstances of the attack she suffered. Instead, the majority engages in misdirection, noting there were “other spaces where a rape could take place” (maj. opn., ante, at pp. 772, 111), and in “mere speculation . . . unsupported by any proven facts” (Showalter v. Western Pacific R. R. Co. (1940) 16 Cal. 2d 460, 478 [106 P.2d 895]) as to a possible defense, observing that plaintiff’s assailants “could have been tenants” (maj. opn., ante, at p. 776).3
Again invoking policy, the majority expresses concern that “the ultimate costs of imposing liability for failure to provide sufficient daytime security to prevent assaults would be passed on to the tenants of low-cost housing . . . , adding to the financial burden on poor renters.” (Maj. opn., ante, at p. 111.) The majority does not mention the economic cost to tenants of allowing crime to flourish. As noted earlier in this opinion, such policy considerations relate principally to duty rather than causation. But even assuming the relevance of the assertion, and assuming in addition the truth of the majority’s unstated and unsupported premise that neither market forces nor regulation would cause landlords to absorb reasonable security costs, unlike the majority I am unwilling to assume that California renters, of whatever economic status, would elect to live in circumstances where they and their guests are subject to constant fear and, as in this case, the actuality of rampant crime and violent assault, in preference to a marginal upward pressure on rents.
Regrettably, plaintiff’s “assailants were never apprehended and their identity remains unknown to her” (maj. opn., ante, at p. 767). That she should be barred from the courthouse for this very reason, is both cruelly ironic and legally unjustified.
*795For the foregoing reasons, I would affirm the judgment of the Court of Appeal and allow plaintiff to proceed with her claim.
Mosk, J., and Kennard, J., concurred.
See, e.g., Bockrath v. Aldrich Chemical Co. (1999) 21 Cal.4th 71, 79 [86 Cal.Rptr.2d 846, 980 P.2d 398] (noting in cases “presenting complicated . . . medical causation issues, the standard of proof ordinarily required is ‘ “a reasonable medical probability based upon competent expert testimony that the defendant’s conduct contributed to [the] plaintiff’s injury” ’ ”); State Farm Fire & Casualty Co. v. Von Der Lieth (1991) 54 Cal.3d 1123, 1132 [2 Cal.Rptr.2d 183, 820 P.2d 285, 30 A.L.R.5th 786] (noting “expert testimony overwhelmingly supported the jury’s determination that the predominating cause of the loss [to homes damaged by earth movement] was third party negligence”); Campbell v. General Motors Corp. (1982) 32 Cal.3d 112, 125 [184 Cal.Rptr. 891, 649 P.2d 224, 35 A.L.R.4th 1036] (stating defendant “could have attempted to refute plaintiffs theory of causation by producing evidence (including expert testimony, if desired) that a bar or pole would not have prevented the accident” involving a bus patron’s fall, but “the trial court’s grant of the motion for nonsuit prematurely and erroneously withdrew these issues from the jury”); Seneris v. Haas (1955) 45 Cal.2d 811, 816 [291 P.2d 915, 53 A.L.R.2d 124] (agreeing “error was committed in excluding the expert testimony . . . offered ... in the field of anatomy, biology, pathology, histology and causation”).
Nothing in the majority’s dictum discussing the 1992 and 1993 amendments to Code of Civil Procedure section 437c, the summary judgment statute, undermines these principles. (See maj. opn., ante, at p. 768 [conceding the amendments “ ‘did not change the fundamental requirement that the moving party prove its right to summary judgment’ ” and acknowledging that, as before, defendants must make “a showing that would forecast the inevitability of a nonsuit”].)
In Showalter v. Western Pacific R. R. Co., supra, 16 Cal.2d 460, we upheld as based on substantial evidence a jury’s finding that the defendant employer’s negligence in coupling rail cars proximately caused injury to the deceased (who died after falling from a gondola car), rejecting the employer’s suggestion that, as the “deceased may have tripped or lost his balance for any number of reasons” (id. at pp. 477-478), it was equally possible his death occurred “through unavoidable accident ... or through his own negligence” (id. at p. 477).