v. Buick Motor Co. (1916), which demolished the privity bar to recovery in negligence actions. By 1955, James was citing MacPherson to argue that "[t]he citadel of privity has crumbled," although Maine, the last holdout, would not adopt MacPherson until 1982. The second step was the landmark New Jersey case of Henningsen v. Bloomfield Motors, Inc. (1960), which demolished the privity bar to recovery in actions for breach of implied warranty. Prosser cited Henningsen in 1960 as the "fall of the citadel of privity." The Henningsen court helped articulate the rationale for the imminent shift from breach of warranty (sounding in contract) to strict liability (sounding in tort) as the dominant theory in product liability cases, but did not actually impose strict liability for defective products. The third step was the landmark California case of Greenman v. Yuba Power Products, Inc. (1963), in which the Supreme Court of California openly articulated and adopted the doctrine of strict liability in tort for defective products. Greenman heralded a fundamental shift in how Americans thought about product liability towards a theory of enterprise liability—instead of basing liability on the defendant's "fault" or "warranty", the defendant's liability should be predicated, as a matter of public policy, on the simple question of whether it was part of a business enterprise responsible for inflicting injuries on human beings. The theoretical foundation for enterprise liability had been laid by James as well as another law professor, Leon Green. As noted above, it was Greenman which led to the actual emergence of product liability as a distinct field of private law in its own right. Before this point, products had appeared in case law and scholarly literature only in connection with the application of existing doctrines in contract and tort. The Greenman majority opinion was authored by then-Associate Justice Roger J. Traynor, who cited to his own earlier concurring opinion in Escola v. Coca-Cola Bottling Co. (1944). In Escola, now also widely recognized as a landmark case, Justice Traynor laid the foundation for Greenman with these words: Even if there is no negligence, however, public policy demands that responsibility be fixed wherever it will most effectively reduce the hazards to life and health inherent in defective products that reach the market. It is evident that the manufacturer can anticipate some hazards and guard against the recurrence of others, as the public cannot. Those who suffer injury from defective