In the Early to Mid-1980s,the Court Tended to Be Sympathetic

In the early to mid-1980s,the court tended to be sympathetic to the plaintiffs' position in tort cases,but by the late 1980s this changed.Which of the following is NOT a reason for the change?

A) More justices began to be elected who favored the defendants in civil lawsuits.
B) Republican justices began to be elected.
C) The wave of incoming justices was more conservative than many of the previous justices, who were Democratic.
D) The Reagan era placed a financial cap on what a plaintiff could be awarded from a case.