In its ensuing discussion, the opinion does not mention an important political event subsequent to the decision in Seaman's. The composition of the California Supreme Court changed drastically in 1987 following the bitter and highly contested California judicial retention election of 1986.  For that election, business groups and conservative political groups mounted a massive and ultimately successful campaign to unseat three liberal justices of the California Supreme Court, each of whom had been appointed by Democratic Governor Jerry Brown: Chief Justice Rose Bird, Justice Cruz Reynoso, and Justice Joseph Grodin.  The public face of the campaign urged voters to unseat these justices because of repeated reversals of death penalty convictions, but concern of many of those financing the campaign was with the allegedly "anti-business" decisions of the  "liberal" court, including Seaman's .  Replacements for Justices Bird, Reynoso and Grodin were appointed by Republican Governor George Deukmejian.  One of Governor Deukmejian's appointees, Chief Justice Malcolm Lucas, authors the opinion in this case.  Is Seaman's an "anti-business" decision?   Is this case a "pro-business" decision?