It is true that "but for" Kim and Jimmy's scam, Howard would not have been there. Where do we draw the line?
If Chuck had not pressured Howard to freeze Jimmy out of HHM, or if Chuck had not appointed Howard as trustee so that Howard handed the "fuck you from beyond the grave" letter to Kim, Kim and Jimmy would not have motive to run the scam. Therefore, BUT FOR Chuck's actions.. Howard would still be alive.
Or its the attorneys involved in the Sandpiper Case because they would not settle, drawing the case out. But for them doing that, Kim and Jimmy would have no reason to run the same.
Oh, I know, it's Nacho's fault. Because if Nacho had not told Lalo about Jimmy McGill, he would never have met Lalo and became a friend of the cartel, and then Lalo would never have teleported into their apartment and killed Howard.
That's why causation has to be both foreseeable and proximate.