In Wilson v. John Crane, Inc. (2000) 81 Cal.App.4th 847, the court stated:
"The perceived evil to be eliminated by Proposition 51 was the imposition of liability for noneconomic damages far out of proportion to the defendant's share of responsibility for those damages. We see no reason to believe that the voters thought that evil was any less or different when the defendant was a manufacturer held strictly liable for a defective product, particularly when the statute would unquestionably apply to a manufacturer held liable for negligence. The voters chose to use a legal term of art ('comparative fault') which, as we have seen, embraces all such claims."
Accordingly the court held that Civil Code section 1431.2 applies to strict products liability actions. (81 Cal.App.4th at p. 859.)