During the 1960s, under the aegis of Chief Justice Roger J. Traynor, the California Supreme Court became more liberal and progressive. Traynor's term as Chief Justice (from 1964 to 1970) was marked by a number of firsts: California was the first state to create true strict liability in product liability cases, the first to allow the action of negligent infliction of emotional distress (NIED) even in the absence of physical injury to the plaintiff, and the first to allow bystanders to sue for NIED where the only physical injury was to a relative.