^ See infra note 186 and accompanying text.
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So even if we are prepared to recognize qualified relational moral duties of non-injury, it seems especially difficult to construe the tort of negligence as encoding any plausible instance of this sort of duty (or correlative wrongs) once the holistic culpability-sensitivity of the proximate cause element is brought clearly into view. It is more natural to regard considerations such as a tortfeasor’s holistic culpability for an action and the fortuitous or foreseeable character of the resulting injury, as helping to determine his responsibility for occasioning that injury.169
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