A third way to limit tort burdens placed on deep pocket defendants has been to try to overturn the principle of joint and several liability. Solvent defendants are especially irate about cases where a 5 per cent at fault defendant pays 100 per cent of the damages because the 95 per cent at fault defendant is judgment proof. Some States have responded by eliminating joint and several liability altogether.9 Others decided that defendants are proportionately liable only when their fault is minor. California voters (through the initiative process) decided that defendants are jointly and severally liable for economic losses but not for pain and suffering.1