Which of the Following Was True Prior to the Landmark

Which of the following was true prior to the landmark 1916 case of MacPherson v.Buick Motor Company?

A) Negligence was rarely used as a theory of recovery for an injury caused by a defective product because of the difficulty of establishing the element of duty.
B) Causes of actions against manufacturers of products were barred by an amendment to the U.S.Constitution that has since been repealed.
C) Negligence was rarely used as a theory of recovery for an injury caused by a defective product because of the difficulty of establishing causation.
D) Causes of actions against manufacturers of products were barred under federal law.
E) Negligence was often used as a theory of recovery because of the ease in establishing privity of contract.