534 (explaining that a defendant may rebut substantial causation by establishing that “intervening conduct [was] the sole cause of the end result”). Dorn contends that she did not inflict bodily harm because her pushes did not harm D.E. directly; rather, D.E. was injured only because he tripped over debris and stumbled into the fire. The district court did not make a finding as to whether D.E. tripped over debris, concluding that this determination was not essential because “[D.E.j’s movements were initiated by [Dorn]’s actions.” The court of appeals held that the same “substantial causal factor” standard that applies to “cause” also applies to “infliction,” and that Dorn failed to identify a genuine superseding cause under this standard. Dorn, 875 N.W.2d at 362. “When di h Cir. 2002) (<HOLDING>); United States v. Garcia-Camacho, 122 F.3d
holding that a texas assault statute requiring that the defendant intentionally knowingly or recklessly causes bodily injury to another  may be violated by the defendant so causing such injury by means other than the actual attempted or threatened use of physical force against the person of another and hence does not have such use of force as an element alteration in original holding that the injury was inflicted by the defendant when it occurred while the defendant applied force directly to the victims person holding that the injury was inflicted by the defendant when it occurred as a result of the defendants combative conduct holding that the injury was not inflicted by the defendant when it may have resulted from the actions ie the headbutt of the victim himself holding that a jury could reasonably infer defendant and his brother engaged in victims murder with deliberation where victims hands and feet were bound expert testimony was that victims injuries were inflicted when he was alive defendants gloves were discarded in victims trailer and defendant and his brother burned the trailer in an attempt to conceal the evidence