for the quality of his writing and reasoning, and was honored during his lifetime with membership in the American Academy of Arts and Sciences (a rare honor for a judge). Many of his opinions are still mandatory reading for American law students. Also, Traynor did not uniformly join all opinions that could be characterized as "liberal" or "progressive" during his time on the Court; for example, he filed a two-sentence dissent in the landmark case of Dillon v. Legg (1968), which was a major step towards the modern tort of negligent infliction of emotional distress. His 1948 opinion in Perez v. Sharp was the first instance of a state supreme court striking down a statute prohibiting miscegenation. Traynor also wrote a 1952 opinion that abolished the defense of recrimination in the context of divorce and paved the way for the social revolution of no-fault divorce. But his most significant and well-known contribution to contemporary American law is probably his 1963 creation of true strict liability in product liability cases. An earlier generation of judges had cautiously experimented with legal fictions like warranties to avoid leaving severely injured plaintiffs without any recourse. Traynor simply threw those away and imposed strict liability as a matter of public policy. To those skeptical of government's power to redress social wrongs, Traynor's extraordinary work is notable for the degree to which it asserted the judiciary's power to resolve difficult issues of public policy, and to redefine the boundaries of corporate and governmental liability. In his biography of Traynor, White wrote: "If California was a testing ground for governmental theories of modern liberalism, Traynor was an architect of a judicial role compatible with the activities of the modern liberal state." In July 1983, the California Law Review gave over all its space in issue 4, volume 71 to publishing eloquent tributes to Justice Traynor from several esteemed judges, law professors, and politicians, including Warren Burger, Henry Friendly, and Edmund G. Brown. Criticism The liberal tendencies of much of Traynor's work has since made him the subject of extensive criticism from American libertarians and conservatives, and tort reformers have often grouped Traynor together with Earl Warren as examples of judicial activists. For example, the conservative magazine National Review attacked Traynor's reasoning in the Pacific Gas and Electric Company case (Pacific Gas & Elec. Co. v. G. W. Thomas Drayage Co., 69 Cal. 2d 33 (1968)) in a