1.   The common law was opposed to actions in tort and the landlord was immune from a tort action in respect of dangerous premises.

2.   Generally speaking, there is no tort action where the product is merely defective and has not caused any physical damage.

3.   If, however, an exception to the FTCA shields the United States from suit, the plaintiff may be left without a tort action against any party.

4.   The mere threat of tort actions could discourage some news organizations from aggressive reporting that is within the bounds of ethical conduct.