The Pennsylvania Commonwealth Court ruled in DeWeese v. Weaver, 880 A.2d 54 (Pa. Cmwlth. 2005) that the "Fair Share Act," a reform of the joint and several liability doctrine, was unconstitutional. In response, Senate Bill 435 was moved through the Legislature and presented to Governor Ed Rendell for signature. This Bill provided for that defendants would only have to pay the portion of damages proportionate to their liability, unless they were at least 60% liable or their actions were intentional.