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substance murder under section 609.195(b).2 To find the applicable law concerning proximate cause in a prosecution for third- degree controlled-substance murder, we look to the 2013 Smith opinion, in which the supreme court stated, “to prove proximate cause, the State must show that the defendant’s acts were a substantial factor in causing the death.” d at 4 ().

534 (Minn. 1989) (applying the substantial-factor test to second-degree murder and first-degree manslaughter); -41 (Minn. 1986) (applying the “substantial causal factor” test to first-degree murder).

See State v. Olson , d 530, 534 n.4 (Minn. 1989) (noting that jury instruction in a homicide case which explains “that the state must prove beyond a reasonable doubt that defendant’s acts had a substantial part in bringing about the child’s death” adequately a ddresses causation).

Cause, in a criminal context, requires o nly that the defendant’s acts were a “substantial causal factor.” ().

State v. Olson , d 530, 534 (Minn. 1989) (“It must be shown th at the defendant’s acts injured the [victim’s] brain which then led to the [victim’s] death.”).

See Smith, d at 4; -35 n.4 (Minn. 19 89) (“[I]t is not necessary that the defendant’s acts be the sole cause of death, so long as the defendant’s acts start a chain of events which results in or substantially contributes to the death.”).

15, 2000); d 134, 146 (Minn. 2011) (explaining that when “cause” is used in homicide statute, prosecution must prove that defendant’s acts were a “substantial causal factor” resulting in death); 534 (Minn. 1989) (“To prove defendant guilty 9 of [second-degree murder and first-degree manslaughter], the state must prove the defendant’s acts were a ‘substantial causal factor’ in causing the [victim’s] death.”); State v. Sutherlin , -41 (Minn. 1986 ) (sustaining first-degree murder

(explaining that under a homicide statute in which the word “cause” is used, the State need only prove that the defendant’s acts were a “ ‘substantial causal factor’ leading to the death” (quoting State v. 10 Olson, ); see also Olson, d at 534 (explaining that a defendant may rebut substantial causation by establishing that “intervening conduct [was] the sole cause of the end result”).

See, (noting that to prove the defendant guilty of second-degree murder and first-degree manslaughter, the state must prove that the defendant’s actions were a “substantial causal factor” in causing death).

(quotation omitted) (explaining that Minnesota applies the civil substantial factor definition of causation in criminal vehicular homicide and operation cases); (holding that defendant’s actions were a substantial factor if he “injured the victim, which in turn led to the victim’s death”) ().