In November 1986, Chief Justice Rose Bird and two fellow liberal colleagues were ejected from the court by the state's electorate for opposing the death penalty. Bird's replacement, Chief Justice Malcolm M. Lucas, authored an opinion in 1988 that adopted Richardson's strict constructionist view with regard to the interpretation of the California Insurance Code. A 2008 decision by the Court of Appeal and a 2010 decision by the Supreme Court itself finally established that Justice Richardson's strict constructionism as adopted by the Lucas court would "retroactively" apply to all California statutes. In the 2010 decision in "Lu v. Hawaiian Gardens Casino", Justice Ming Chin wrote for a unanimous court that "we begin with the premise that a violation of a state statute does not necessarily give rise to a private cause of action."