(North Carolina's judiciary never attempted to adopt the doctrine, and the state legislature enacted a statute expressly banning strict liability for defective products in 1995.) In a landmark 1986 decision, the U.S. Supreme Court also embraced strict liability for defective products by adopting it as part of federal admiralty law. Factors behind nationwide adoption In the conventional narrative, there are two main factors that explain the rapid embrace of Greenman and Section 402A. First, they came along just as Americans were coalescing around a consensus in favor of consumer protection, which would eventually cause Congress to enact several landmark federal product safety and vehicle safety statutes. Between 1960 and 1977, Congress passed at least forty-two laws dealing with consumer and worker safety. Second, American academic experts in the field of law and economics developed new theories that helped to justify strict liability, such as those articulated by Guido Calabresi in The Costs of Accidents (1970). To this, Kyle Graham adds three more factors: (3) the rise of attorneys specializing exclusively in plaintiffs' personal injury cases and their professional associations like the organization now known as the American Association for Justice; (4) the ubiquity of so-called "bottle cases" (personal injury cases arising from broken glass bottles) before aluminum cans and plastic bottles displaced glass bottles as the primary beverage container during the 1970s; and (5) the resistance of the Uniform Commercial Code's editorial board to extending warranties to bystander victims before 1966—in states whose legislatures had not already acted, state courts were more receptive to extending the common law to grant bystanders a strict liability tort claim. Prosser inexplicably imposed in Section 402A a requirement that a product defect must be "unreasonably dangerous." Since the "unreasonably dangerous" qualifier implicitly connotes some sense of the idea of "fault" which Traynor was trying to exorcise from product liability, it was subsequently rejected as incompatible with strict liability for defective products by Alaska, California, Georgia, New Jersey, New York, Puerto Rico and West Virginia. The mass tort product liability explosion Early proponents of strict liability believed its economic impact would be minor because they were focused on manufacturing defects. They failed to foresee the logical implications of applying the rule to other types of product defects. Only in the late 1960s did Americans begin to draw a clear analytical distinction between manufacturing and design defects, and since the early 1980s, defective design claims "have