Efficient Proximate Cause Doctrine West Virginia

The efficient proximate cause doctrine was adopted by this Court in Murray v. State Farm Fire & Casualty Co., 203 W. Va. 477, 509 S.E.2d 1 (1998). Pursuant to that doctrine: When examining whether coverage exists for a loss under a first-party insurance policy when the loss is caused by a combination of covered and specifically excluded risks, the loss is covered by the policy if the covered risk was the efficient proximate cause of the loss. No coverage exists for a loss if the covered risk was only a remote cause of the loss, or conversely, if the excluded risk was the efficient proximate cause of the loss. The efficient proximate cause is the risk that sets others in motion. It is not necessarily the last act in a chain of events, nor is it the triggering cause. The efficient proximate cause doctrine looks to the quality of the links in the chain of causation. the efficient proximate cause is the predominating cause of the loss.