In Hazine v. Montgomery Elevator Co., 176 Ariz. 340, 344, 861 P.2d 625, 629 (1993), the Arizona Supreme Court held a cause of action for strict product liability was protected by the anti-abrogation clause. Id. at 345, 861 P.2d at 630. The court concluded it was "totally irrelevant" that Arizona did not recognize the tort until the 1960s because, "while not universally applied to product liability cases until recent times, theories of strict and even absolute liability were recognized in tort law well before 1912." Id. at 344, 861 P.2d at 629.