Some business interests argue the court should leave any change to the legislature. But Maryland judges, not the legislature, created contributory negligence in the mid-19th century. In the past half-century, 45 states have modified contributory negligence by adopting comparative fault, which reduces — but does not eliminate — the victim's award of damages when both parties are at fault. In many states, including Florida, Illinois, and California, the courts, not the legislature, made the change. Despite apocalyptic warnings from lobbyists for some Maryland businesses, life goes on in those jurisdictions. In fact, a return to contributory negligence does not even appear to rank high in the tort reform agenda of businesses and insurance companies in other states.