Some states have developed their own tests independently of the "Borak", "Cort", and "Sandoval" line of federal cases. For example, prior to 1988, California courts used a vague liberal construction test, under which "any" statute "embodying a public policy" was privately enforceable by any injured member of the public for whose benefit the statute was enacted. This was most unsatisfactory to conservatives on the Supreme Court of California, such as Associate Justice Frank K. Richardson, who articulated a strict constructionist view in a 1979 dissenting opinion. As Richardson saw it, the Legislature's "silence" on the issue of whether a cause of action existed to enforce a statute should be interpreted as the Legislature's intent to "not" create such a cause of action.