R. v. Nette, 3 S.C.R. 488, 2001 SCC 78, is a leading Supreme Court of Canada decision on the standard for causation in criminal offences. The Court upheld the Smithers test for causation in a criminal charge for manslaughter or murder but held that the test for causation for second degree murder need not be expressed as "a contributing cause of death, outside the de minimis range". Instead, it would be more preferable to use positive terms such as "significant contributing cause". In the case of first degree murder under s. 231(5) of the Code (crime of domination), a jury must also consider the additional R. v. Harbottle "a substantial causation" standard but only after finding the accused guilty of murder.