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(n214) Id. at 195.

(n215) Id. at 195-96

(n216) Id. at 196.

(n217) Id.

(n218) Id.

(n219) Id. at 197.

(n220) Id.

(n221) Id.

(n222) Id. at 198-99.

(n223) See Steenson, supra note 158, at 485-86, describing several statutes that limit the operation of joint and several liability when the defendant's fault is found to be less than a threshold percentage, or less than the claimant's percentage of fault. For example, a 1986 Alaska statute provided that, when defendants are found less than 50% at fault, their damages are capped at no more than twice their culpability percentages. The Alaska legislature has since moved further: the above statute was replaced with ALASKA REV. STATS. Section 09.17.080 (1987) which provides for several only liability. See also N.J. STAT. ANN. Section 2A:15-5.3(a) (1987) which provides that defendants found 20% or less at fault are responsible only for that percentage attributable to their negligence, and defendants 21 to 59% at fault are subject to joint and several liability only for economic damages. See MeBride, supra note 202, at 175-76. Presumably these limitation provisions imply recognition by state legislatures that feet finders should be permitted to shift liability from insolvent to solvent tortfeasors only when the solvent party is a major contributor to the harm. Presumably, parties who are only peripherally involved in harm-causing enterprises are likely to be deemed only minor contributors to the harm. But see supra note 25.

(n224) See MaePherson v. Buick Motor Co., 111 N.E. 1050 (N.Y. 1916); Henningsen v. Bloomfield Motor Inc. 161 A.2d 69 (N.J. 1960). In both of these major assaults on privity -- the one on the negligence barrier, the other on that imposed by warranty -- the danger to the person was singled out to justify the attacks. This distinction in the nature of the injury at issue was also emphasized in Ultramares. See supra note 13 and accompanying text.

(n225) See Victor P. Goldberg, Accountable Accountants, Is Third Party Liability Necessary', 17 J. LEGAL STUD. 301-02 (describing contractual, insurance-like mechanisms for shifting risk in creditor-investor eases).

(n226) Wade, supra note 158, at 202 ("The conduct of each defendant is then a proximate cause of the collision and therefore of the whole resulting injury to the plaintiff."); Wright, supra note


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