1957; a similar situation occurred in the U.S. State of California in which a judicial common law rule established in Rowland v. Christian was amended through a 1985 statute. Statutory torts also spread across workplace health and safety laws and health and safety in food. In some cases, federal or state statutes may preempt tort actions, which is particularly discussed in terms of the U.S. FDA Preemption; although actions in the United States for medical devices are preempted due to Riegel v. Medtronic, Inc. (2008), actions for medical drugs are not due to Wyeth v. Levine (2009). Comparison with other areas of law Tort law is closely related to other areas of law, particularly contract and criminal law. On one hand, tort and contract law are typically regarded as the two primary fields within the law of obligations, with tort forming a catch-all category encompassing civil wrongs that arise by operation of law in contrast to breach of contract, which encompasses violations of obligations that are freely assumed by parties to a contract. On the other hand, both tort and criminal law aim to address wrongful conduct and often overlap such that conduct which gives rise to a claim under tort law may also give rise to a prosecution under criminal law. Contract law Tort is sometimes viewed as the causes of action which are not defined in other areas such as contract or fiduciary law. However, tort and contract law are similar in that both involve a breach of duties, and in modern law these duties have blurred and it may not be clear whether an action "sounds in tort or contract"; if both apply and different standards apply for each (such as a statute of limitations), courts will determine which is the "gravamen" (the most applicable). Circumstances such as those involving professional negligence may involve both torts and contracts. The choice may affect time limits or damages, particularly given that damages are typically relatively limited in contract cases while in tort cases noneconomic damages such as pain and suffering may be awarded. Punitive damages are relatively uncommon in contractual cases versus tort cases. However, compensation for defective but not unsafe products is typically available only through contractual actions through the law of warranty. In the United Kingdom, plaintiffs in professional negligence cases have some degree of choice in which law while in commercial transactions contract law applies; in