he or she suffered injury; the closeness of the connection between the defendant's conduct and the injury suffered; the moral blame attached to the defendant's conduct; the policy of preventing future harm; the extent of the burden to the defendant and the consequences to the community of imposing a duty of care with resulting liability for breach; and the availability, cost, and prevalence of insurance for the risk involved. A 1997 case added to this: the social utility of the defendant's conduct from which the injury arose. Contemporary California appellate decisions treat the Rowland decision as the "gold standard" for determining the existence of a legal duty of care, and generally refer to the criteria for determining the existence of a legal duty of care as the Rowland factors. In California, the duty inquiry focuses on the general category of conduct at issue and the range of foreseeable harm it creates, rather than the specific actions or injuries in each case. Appellate lawyer Jeffrey Ehrlich persuaded the California Supreme Court to clarify the central importance of this distinction with its 2011 decision in Cabral v. Ralphs Grocery Co. which requires "no duty" rulings to be based on categorical public-policy rules that can be applied to a range of cases, without reference to detailed facts. By requiring courts to apply the Rowland factors at this high level of factual generality, the Cabral decision preserved the role of juries in determining whether the defendant breached its duty of care based on the unique circumstances of each case. A majority of U.S. states have adopted some kind of multi-factor analysis based on the work of Prosser and others. Some states simply copied California's factors but modified them, like Michigan (which deleted the insurance factor and never picked up the social utility factor), while others developed different lists of factors, such as this one from Tennessee: the foreseeability of the harm or injury; the possible magnitude of the potential harm or injury; the importance or social value of the activity engaged in by the defendant; the usefulness of the conduct to the defendant; the feasibility of alternative conduct; the costs and burdens associated with the alternative conduct; the relative usefulness of the alternative conduct; and the relative safety of the alternative conduct. A 2011 law review article identified 43 states that use a multifactor analysis in 23 various incarnations; consolidating them together results in