only raised premiums and a higher risk rating as the potential consequence, and no jury awards or legal settlements. Detractors of no-fault also point out that legitimate victims with subtle handicaps find it difficult to seek recovery under no-fault. Another criticism is that some no-fault jurisdictions have among the highest automobile-insurance premiums in the country, but this may be more a matter of effect than cause: the financial savings from no-fault may simply make it more popular in areas with higher automobile-collision risk, or high insurance rates may cause more drivers to go uninsured, increasing the attraction of a no-fault system. Origins The number of traffic accidents causing fatalities and debilitating injuries had become by the mid-1960s the source of a litigation explosion that was "straining (and in some areas overwhelming) the judicial machinery." Much legal thinking in academia was devoted to the question of whether the tort system should be replaced with another method of allocating risks of loss from accidents. Empirical analyses were published showing the financial impact of automobile accidents. The first comprehensive legislative proposal was put forward by Professors Robert E. Keeton of Harvard Law School and Jeffrey O'Connell, then of the University of Illinois, in a law review article published in the Harvard Law Review, which consisted of two chapters of the book that they would publish the following year. The Keeton-O'Connell plan provided that all automobile owners would be required to purchase a new form of insurance, called "basic protection coverage," under which a victim has recourse for his net economic loss against the insurer of his own car, his host's car or, if the victim is a pedestrian, any car involved. Fault is not required to be shown except for of damages in excess of $10,000 for bodily injury, the deductible of $100 for bodily injury and property damage. Recoverable loss under this type of policy does not include pain and suffering and is reduced by damages recovered from other sources. The proposal generated immense discussion in legal and insurance publications with some concluding it was too "revolutionary." In 1967 Massachusetts state representative Michael Dukakis, a 1960 graduate of Harvard Law School, introduced a modified version of the Keeton-O'Connell plan in the Massachusetts legislature. The scheme was adopted in 1970. The law was challenged in court for claimed violations of numerous state and federal constitutional provisions. The scheme was defended by the state