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

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 were more conservative than many of the previous justices, who were Democratic.
D) Interest groups that were harmed by the pro-plaintiff tendencies of the court began to organize, raising and spending money for elected justices sympathetic to their perspectives.
E) The Reagan era placed a financial cap on what a plaintiff could be awarded from a case.