That “but for” argument doesn’t fly. Because it would allow standing for anyone. “But for” Expedia, I would not have bought that flight and would not have been on it when it crashed.
No, the "but for" argument can apply only to a party who commits an act in a chain of causation linking that act to an injury to the plaintiff. It does not apply not to "anyone".
If Donofrio is granted the right to quo warranto against Obama, I expect him to allege that Obama's usurpation of a federal office to which he was not entitled is the first tortious act in a chain of acts (including appointment of Car Czar) leading to injury of the Chrysler dealers (extinction of their franchise rights).
Under the "but for test" Obama can be liable and subject to a quo warranto challenge regardless of failure by the Chrysler dealers to only partially mitigate their injury with a timely appeal of a still onerous and injurious pre-sale-to-Fiat franchise negotiation as opposed to post-sale-to-fiat franchise negotiation.
See:
http://legal-dictionary.thefreedictionary.com/But+for+test
"An act from which an injury results as a natural, direct, uninterrupted consequence and without which the injury would not have occurred.
"Proximate cause is the primary cause of an injury. It is not necessarily the closest cause in time or space nor the first event that sets in motion a sequence of events leading to an injury. Proximate cause produces particular, foreseeable consequences without the intervention of any independent or unforeseeable cause. It is also known as legal cause.
"To help determine the proximate cause of an injury in Negligence or other tort cases, courts have devised the "but for" or "sine qua non" rule, which considers whether the injury would not have occurred but for the defendant's negligent act. A finding that an injury would not have occurred but for a defendant's act establishes that the particular act or omission is the proximate cause of the harm, but it does not necessarily establish liability since a variety of other factors can come into play in tort actions."