In Chadwick v. Fire Ins. Exchange (1993) 17 Cal.App.4th 1112, substandard design and construction of the wall and floor framing caused cracks in the walls. (Id. at p. 114.) The insurance policy excluded coverage for damage caused by latent defects in construction. The plaintiffs argued the defective framing was the result of a nonexcluded peril, negligent construction, which was the "efficient proximate cause" of the damages. (Id. at p. 1116.) The court rejected this contention as sophistry, explaining: "California courts have consistently applied the efficient proximate cause analysis where two or more distinct actions, events or forces combined to create the damage. . . .When, however, the evidence shows the loss was in fact occasioned by only a single cause, albeit one susceptible to various characterizations, the efficient proximate cause analysis has no application. An insured may not avoid a contractual exclusion merely by affixing an additional label or separate characterization to the act or event causing the loss." (Id. at p. 1117.) The court continued: "Whether characterized as negligent, intentional or innocently inadvertent, the peril itself--the defective framing--is one and the same. To say builder negligence 'caused' the defective framing is, in this context, to indulge in misleading wordplay, akin perhaps to saying a murderer's malice aforethought 'caused' the killing." (Id. at p. 1118.)