must apply because these were "warranty" actions, though there was often no contract involved. See id. at 690-91. In response to the difficulties of attempting to apply contract rules to products liability cases in the absence of a contract, courts moved away from the implied warranty theory of recovery and adopted a strict liability in tort theory. A tort theory based on the dangerousness of conduct was considered more appropriate and more adaptable than a contract theory because the policy reasons courts were supplying to justify the imposition of strict lability go far beyond any conventional contract notions. See id. at 692. The California Supreme Court led the way with its decision in Greenman v. Yuba Power Products, Inc., 59 Cal.2d 57, 27 Cal.Rptr. 697, 377 P.2d 897, 900 (1963)(<HOLDING>), and the American Law Institute followed with
recognizing that a manufacturer may be held strictly liable for subsequent changes to an otherwise safe product where such alterations are reasonably foreseeable holding that a party can be liable in tort for actions authorized by the contract holding manufacturer liable for defective product provided that plaintiff could not by exercise of reasonable care have discovered the defecl and perceived its danger or otherwise averted his injury holding that plaintiff had successfully traced the defective condition to the manufacturer where there was no evidence of tampering by the retailer holding a manufacturer strictly liable in tort for injury to plaintiff caused by defective power tool