loss of consortium claim (Connecticut) · Go Syfert
← Connecticut issues

loss of consortium claim in Connecticut

71 Connecticut opinions name it 3 courts 1979–2025 3 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (31)

CaseFollowedCited
Mahoney v. Lensinkgreen
connappct · 1988 · cited in 4 Connecticut opinions naming this issue, 1992–1995
2 sentences

1995"No appellate court case has yet addressed squarely the issue of whether, under any circumstances, a cause of action for the loss of filial consortium lies." Mahoney v. Lensink , 17 Conn. App. 130 , 141 (footnote) (1988).

1994See Mahoney v. Lensink , 17 Conn. App. 130 , 141 , 550 A.2d 1088 (1988), rev'd on other grounds , 213 Conn. 548 , 569 A.2d 518 (1990); Hopson v. St.

24
Mahoney v. Lensinkgreen
conn · 1990 · cited in 3 Connecticut opinions naming this issue, 1992–1994
2 sentences

1994See Mahoney v. Lensink , 17 Conn. App. 130 , 141 , 550 A.2d 1088 (1988), rev'd on other grounds , 213 Conn. 548 , 569 A.2d 518 (1990); Hopson v. St.

1994See Mahoney v. Lensink , 17 Conn. App. 130 , 141 , 550 A.2d 1088 (1988), rev'd on other grounds , 213 Conn. 548 , 569 A.2d 518 (1990); Hopson v. St.

23
Bifolck v. Philip Morris, Inc.green
conn · 2016 · cited in 2 Connecticut opinions naming this issue, 2021–2021
2 sentences

2021See footnote 2 of this opinion. 6 The plaintiff argues that the trial court improperly relied on § 20 of the Restatement (Third) of Torts because the ‘‘[a]doption of [the Restatement (Third) of Torts] for product liability claims has been rejected in Connecti- cut.’’ The plaintiff relies on Bifolck v. Philip Morris, Inc., 324 Conn. 402 , 408, 152 A.3d 1183 (2016), in which this court declined to adopt the Restatement (Third) or to make any substantive changes to our product liability tests, instead favoring ‘‘modest refinements’’ to the approach under the Restatement (Second).

2021See footnote 2 of this opinion. 6 The plaintiff argues that the trial court improperly relied on § 20 of the Restatement (Third) of Torts because the ‘‘[a]doption of [the Restatement (Third) of Torts] for product liability claims has been rejected in Connecti- cut.’’ The plaintiff relies on Bifolck v. Philip Morris, Inc., 324 Conn. 402 , 408, 152 A.3d 1183 (2016), in which this court declined to adopt the Restatement (Third) or to make any substantive changes to our product liability tests, instead favoring ‘‘modest refinements’’ to the approach under the Restatement (Second).

22
Voris v. Molinarogreen
conn · 2011 · cited in 2 Connecticut opinions naming this issue, 2017–2019
2 sentences

2019See also Voris v. Molinaro , supra, 302 Conn. at 797 -801 , 31 A.3d 363 (affirming judgment rendered upon trial court's granting of defendant's motion to strike loss of consortium claim on ground that predicate negligence claim brought by plaintiff's spouse had been settled).

2019See also Voris v. Molinaro , supra, 302 Conn. at 797 -801 , 31 A.3d 363 (affirming judgment rendered upon trial court's granting of defendant's motion to strike loss of consortium claim on ground that predicate negligence claim brought by plaintiff's spouse had been settled).

22
Izzo v. Colonial Penn Insurancegreen
conn · 1987 · cited in 8 Connecticut opinions naming this issue, 1994–2017
2 sentences

2017The court in Izzo identified the critical question as whether the loss of consortium claim arose "out of bodily injury sustained by 'one person' so as to make the 'per person' limit applicable, or is [a loss of consortium claim] a claim for bodily injury to a second person such as to invoke the 'per occurrence' limit." (Emphasis added.) Id., at 309 , 524 A.2d 641 .

2017The court in Izzo identified the critical question as whether the loss of consortium claim arose "out of bodily injury sustained by 'one person' so as to make the 'per person' limit applicable, or is [a loss of consortium claim] a claim for bodily injury to a second person such as to invoke the 'per occurrence' limit." (Emphasis added.) Id., at 309 , 524 A.2d 641 .

18
Champagne v. Raybestos-Manhattan, Inc.green
conn · 1989 · cited in 7 Connecticut opinions naming this issue, 1991–2000
2 sentences

2000A loss of consortium claim is "dependant for its assertion. on the legal viability of the cause of action in the injured party." Champagne v. Raybestos-Manhattan, Inc., 212 Conn. 509 , 564 , 562 A.2d 1100 (1989).

2000A loss of consortium claim is "dependant for its assertion. on the legal viability of the cause of action in the injured party." Champagne v. Raybestos-Manhattan, Inc., 212 Conn. 509 , 564 , 562 A.2d 1100 (1989).

17
Lynn v. Haybuster Manufacturing, Inc.green
conn · 1993 · cited in 4 Connecticut opinions naming this issue, 1994–1999
2 sentences

1999The Supreme Court examined whether a loss of consortium claim could be maintained in the context of a products liability case in Lynn v. Haybuster Manufacturing, Inc. , 226 Conn. 282 , 289 , 627 A.2d 1288 (1993).

1999The Supreme Court examined whether a loss of consortium claim could be maintained in the context of a products liability case in Lynn v. Haybuster Manufacturing, Inc. , 226 Conn. 282 , 289 , 627 A.2d 1288 (1993).

14
Keough, Admx. v. Keoughgreen
connsuperct · 1940 · cited in 4 Connecticut opinions naming this issue, 1993–1994
2 sentences

1994This court agrees with the reasoning of Judge Wagner in Toscano , supra, and holds that Connecticut does not allow a loss of consortium claim by a child based on injuries to a parent.

1993This court agrees with the reasoning of Judge Wagner in Toscano, supra, and holds that Connecticut does not allow a loss of consortium claim by a child based on injuries to a parent.

14
Gurliacci v. Mayergreen
conn · 1991 · cited in 3 Connecticut opinions naming this issue, 1992–2016
2 sentences

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

13
Musorofiti v. Vlcekgreen
connappct · 2001 · cited in 2 Connecticut opinions naming this issue, 2001–2007
2 sentences

2001The recent case of Musorofiti v. Vlcek, 65 Conn. App. 365 , ___ A.2d ___ (2001), discusses a loss of consortium claim at some length and defines such a claim as one that involves "the loss of services, financial support, and the variety of intangible relations that exist between spouses living together in marriage." (Citations omitted; internal quotation marks omitted.) Id., 372 .

2001The recent case of Musorofiti v. Vlcek, 65 Conn. App. 365 , ___ A.2d ___ (2001), discusses a loss of consortium claim at some length and defines such a claim as one that involves "the loss of services, financial support, and the variety of intangible relations that exist between spouses living together in marriage." (Citations omitted; internal quotation marks omitted.) Id., 372 .

12
Parker v. Shaker Real Estate, Inc.green
connappct · 1998 · cited in 2 Connecticut opinions naming this issue, 1999–1999
2 sentences

1999Due to the derivative nature of this cause of action, the Appellate Court has upheld trial court decisions directing a verdict on a loss of consortium claim following dismissal of the injured spouse's claims; Parker v. Shaker Real Estate, Inc. , 47 Conn. App. 489 , 496 , 705 A.2d 210 (1998); and striking a loss of consortium claim where the injured spouse's claims were stricken; Greene v. Metals Selling Corp. , 3 Conn. App. 40 , 47 , 484 A.2d 478 (1984).

1999Due to the derivative nature of this cause of action, the Appellate Court has upheld trial court decisions directing a verdict on a loss of consortium claim following dismissal of the injured spouse's claims; Parker v. Shaker Real Estate, Inc. , 47 Conn. App. 489 , 496 , 705 A.2d 210 (1998); and striking a loss of consortium claim where the injured spouse's claims were stricken; Greene v. Metals Selling Corp. , 3 Conn. App. 40 , 47 , 484 A.2d 478 (1984).

12
Allen v. Endrukaitisgreen
connsuperct · 1979 · cited in 2 Connecticut opinions naming this issue, 1993–1996
2 sentences

1996In Allen v. Endrukaitis, 35 Conn. Sup. 286 (1979), Judge Satter rejected the California rule and concluded that the statute of limitations for loss of consortium purposes should related back to the date of the spouse's injury claim and not the date of that injury.

1993See, e.g., Allen v. Endrukaitis, 35 Conn. Sup. 286 , 408 A.2d 673 (Super.Ct. 1979) (original plaintiff's claim for loss of consortium added to his complaint after the statute of limitations had passed, survived a motion to strike); Micherino v. Shanley, 2 CSCR 729 (June 16, 1987, Spear, J.) (wife's motion to intervene in husband's malpractice action so as to include her claim for loss of consortium, filed after expiration of statute of limitations, was denied).

12
Golub v. Chrysler Corporation, No. Cv 91 0501082 (Oct. 22, 1992)green
connsuperct · 1992 · cited in 2 Connecticut opinions naming this issue, 1993–1993
2 sentences

1993I believe the sounder decision in this regard is found in Golub v. Chrysler Corp., 7 CSCR 1295 (October 22, 1992, Hennessey, J.), where it was held that a product liability statute does not permit a loss of consortium claim by the spouse of the one injured by the product.

1993See also Golub v. Chrysler Corporation, 7 CSCR 1295 , 1296 (1992) (Hennessey, J.) holding that the Products Liability Act, section 52-572m et seq., does not allow a derivative loss of consortium claim by the spouse of a person injured by a defective product.

12
Gilman v. Shamesgreen
connappct · 2019 · cited in 1 Connecticut opinions naming this issue, 2025–2025
2 sentences

2025See Gilman v. Shames, 189 Conn. App. 736 , 747–48, 208 A.3d 1279 (2019) (‘‘Like a loss of consortium claim, a claim for bystander emotional distress is a derivat[ive] claim. . . .

2025See Gilman v. Shames, 189 Conn. App. 736 , 747–48, 208 A.3d 1279 (2019) (‘‘Like a loss of consortium claim, a claim for bystander emotional distress is a derivat[ive] claim. . . .

11
Lawrence v. Texasgreen
scotus · 2003 · cited in 1 Connecticut opinions naming this issue, 2014–2014
11
Moore v. McNamaragreen
conn · 1986 · cited in 1 Connecticut opinions naming this issue, 2014–2014
11
Hooten v. Pennsylvania College of Optometrygreen
paed · 1984 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Jones v. Elliottgreen
del · 1988 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Rosander v. Copco Steel & Engineering Co.green
indctapp · 1982 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Burke v. L & J Food & Liquor, Inc.green
moctapp · 1997 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Desjarlais v. USAA Insurance Co.green
ri · 2003 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Steele v. Botticellogreen
me · 2011 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Zuniga v. Dwyergreen
illappct · 2001 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Swartz v. United States Steel Corporationgreen
ala · 1974 · cited in 1 Connecticut opinions naming this issue, 2011–2011
11
Marshall v. Hartford Hospitalgreen
conn · 2001 · cited in 1 Connecticut opinions naming this issue, 2007–2007
11
New Haven Savings Bank v. LaPlacegreen
conn · 2001 · cited in 1 Connecticut opinions naming this issue, 2007–2007
11
Clarke v. Comissioner of Correctiongreen
conn · 1996 · cited in 1 Connecticut opinions naming this issue, 2001–2001
11
Borkowski v. Sachetigreen
conn · 1996 · cited in 1 Connecticut opinions naming this issue, 2001–2001
11
Peter-Michael, Inc. v. Sea Shell Associatesgreen
conn · 1998 · cited in 1 Connecticut opinions naming this issue, 2001–2001
11
Borkowski v. Sachetigreen
connappct · 1996 · cited in 1 Connecticut opinions naming this issue, 2001–2001
11
Bhinder v. Sun Co.green
conn · 1998 · cited in 1 Connecticut opinions naming this issue, 1999–1999
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (49)

CaseCitedYears
Jacoby v. Brinckerhoff green
conn · 1999
2 sentences

2019Our Supreme Court's decision in Jacoby v. Brinckerhoff , supra, 250 Conn. 86 , 735 A.2d 347 , which analyzed the viability of a plaintiff's loss of consortium claim in the absence of a predicate action commenced by the plaintiff's former spouse, is instructive, however.

2019Our Supreme Court's decision in Jacoby v. Brinckerhoff , supra, 250 Conn. 86 , 735 A.2d 347 , which analyzed the viability of a plaintiff's loss of consortium claim in the absence of a predicate action commenced by the plaintiff's former spouse, is instructive, however.

52000–2019
Sanzone v. Board of Police Commissioners green
conn · 1991
2 sentences

1993However, the Supreme Court has disallowed a loss of consortium claim related to CT Page 8134 a nuisance or negligence highway defect claim in Sanzone v. Board of Police Commissioners, 219 Conn. 179 (1991).

1992The plaintiffs have agreed to withdraw the fourth count, presumably because Sanzone v. Board of Police Commissioners, 219 Conn. 179 , 199 , holds that a loss of consortium claim is not available where the underlying cause of action is for violation of the highway defects statute, section 13a-149 , which allows recovery only by the injured traveler.

51992–1999
Ladd v. Douglas Trucking Co. green
conn · 1987
2 sentences

2011In support of its conclusion that the settlement of the underlying claim extinguishes a loss of consortium claim, the majority contends that, because our statement to that effect in Hopson was reaffirmed in Ladd v. Douglas Trucking Co., 203 Conn. 187 , 523 A.2d 1301 (1987), and Jacoby v. Brinckerhoff, 250 Conn. 86 , 735 A.2d 347 (1999), disavowing that statement in Hopson would upset the well settled expectations that these cases created.

2011In support of its conclusion that the settlement of the underlying claim extinguishes a loss of consortium claim, the majority contends that, because our statement to that effect in Hopson was reaffirmed in Ladd v. Douglas Trucking Co., 203 Conn. 187 , 523 A.2d 1301 (1987), and Jacoby v. Brinckerhoff, 250 Conn. 86 , 735 A.2d 347 (1999), disavowing that statement in Hopson would upset the well settled expectations that these cases created.

31993–2011
Wesson v. City of Milford green
connappct · 1985
2 sentences

2011Finally, the Appellate Court in Wesson , after observing that the Workers' Compensation Act, General Statutes § 31-275 et seq., provides the exclusive remedy for injuries incurred by employees in the workplace; Wesson v. Milford, supra, 5 Conn.App. at 372 , 498 A.2d 505 ; held that "[t]here is no logical reason why the legislature in 1913 could not have intended to abolish prospective common law derivative causes of action, such as actions for loss of consortium, not then recognized in Connecticut." Id., at 375-76 , 498 A.2d 505 .

2011Finally, the Appellate Court in Wesson , after observing that the Workers' Compensation Act, General Statutes § 31-275 et seq., provides the exclusive remedy for injuries incurred by employees in the workplace; Wesson v. Milford, supra, 5 Conn.App. at 372 , 498 A.2d 505 ; held that "[t]here is no logical reason why the legislature in 1913 could not have intended to abolish prospective common law derivative causes of action, such as actions for loss of consortium, not then recognized in Connecticut." Id., at 375-76 , 498 A.2d 505 .

31993–2011
Hopson v. St. Mary's Hospital green
conn · 1979
2 sentences

2011Mary's Hospital, 176 Conn. 485, 494 , 408 A.2d 260 (1979), to conclude that the plaintiff's loss of consortium claim was barred by the settlement of Voris' negligence claim. [4] The trial court rendered judgment for the defendant and this appeal followed.

2011Mary's Hospital, 176 Conn. 485, 494 , 408 A.2d 260 (1979), to conclude that the plaintiff's loss of consortium claim was barred by the settlement of Voris' negligence claim. [4] The trial court rendered judgment for the defendant and this appeal followed.

31997–2011
Greene v. Metals Selling Corp. green
connappct · 1984
2 sentences

1999Due to the derivative nature of this cause of action, the Appellate Court has upheld trial court decisions directing a verdict on a loss of consortium claim following dismissal of the injured spouse's claims; Parker v. Shaker Real Estate, Inc. , 47 Conn. App. 489 , 496 , 705 A.2d 210 (1998); and striking a loss of consortium claim where the injured spouse's claims were stricken; Greene v. Metals Selling Corp. , 3 Conn. App. 40 , 47 , 484 A.2d 478 (1984).

1999Due to the derivative nature of this cause of action, the Appellate Court has upheld trial court decisions directing a verdict on a loss of consortium claim following dismissal of the injured spouse's claims; Parker v. Shaker Real Estate, Inc. , 47 Conn. App. 489 , 496 , 705 A.2d 210 (1998); and striking a loss of consortium claim where the injured spouse's claims were stricken; Greene v. Metals Selling Corp. , 3 Conn. App. 40 , 47 , 484 A.2d 478 (1984).

31991–1999
Ratick Combustion v. Heating Pip. Cool. Bd., No. 353763 (Jan. 12, 1993) neutral
connsuperct · 1993
2 sentences

1993In Lindsey v. Lindberg Furnace, 8 CSCR 169 (January 12, 1993, Thompson, J.), the court also addressed the issue of whether a loss of consortium claim can be maintained in a PLA action.

1993(Citations omitted.) In Lindsey v. Lindberg Furnace, 8 CSCR 169 (January 12, 1993, Thompson, J.), the court also addressed the issues of whether a loss of consortium claim can be maintained in a product liability action.

31993–1993
Mendillo v. Board of Education red
conn · 1998
2 sentences

2014We further conclude that allowing plaintiffs in Sta- cey’s position to maintain a loss of consortium claim would not undermine any of the public policies that this court identified in Mendillo v. Board of Education, supra, 246 Conn. 456 , when it considered whether it should recognize loss of parental consortium claims.

1999CT Page 3850 The defendant further asks the court to find that a claim for filial consortium cannot stand as a matter of law in light of Mendillo v. Board of Education, 246 Conn. 456 (1998).

21999–2014
Schiano v. Bliss Exterminating Co. green
connappct · 2000
2 sentences

2001The loss of consortium claim asserted by Reine Pelletier in the fifth count is merely derivative of her husband's claim, Schiano v. Bliss Exterminating Co ., 57 Conn. App. 406 , 414 n. 7, (2000).

2000Because the loss of consortium claim asserted by Reine Pelletier in the CT Page 15314 third count is merely derivative of her husband's claims, Schiano v. Bliss Exterminating Co. , 57 Conn. App. 406 , 414 n. 7, ___ A.2d ___ (2000), judgment also enters for Sordoni on the third count of the amended complaint.

22000–2001
Marri v. Stamford Street Railroad Co. green
· 1911
2 sentences

1993Co., 84 Conn. 9, 14-17 , 78 A. 582 (1911); the right of a wife to bring a loss of consortium claim was not recognized until well into the twentieth century.

1993Co., 84 Conn. 9, 14-17 , 78 A. 582 (1911); the right of a wife to bring a loss of consortium claim was not recognized until well into the twentieth century.

21992–1993
Park Regional Corporation v. Town Plan & Zoning Commission green
conn · 1957
2 sentences

1993Park Regional Corporation v. Town Plan & Zoning Commission, 144 Conn. 677, 682 , 136 A.2d 785 (1957).

1993Park Regional Corporation v. Town Plan & Zoning Commission, 144 Conn. 677, 682 , 136 A.2d 785 (1957).

21993–1993
O'Connor v. O'Connor green
conn · 1986
2 sentences

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

12016–2016
Ozyck v. D'Atri green
conn · 1988
12016–2016
Lisee v. Commission on Human Rights & Opportunities green
conn · 2001
12016–2016
Craig v. Driscoll green
conn · 2003
2 sentences

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

12016–2016
Morel v. Commissioner of Public Health green
conn · 2002
2 sentences

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

12016–2016
Commission on Human Rights & Opportunities v. Board of Education green
conn · 2004
2 sentences

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

12016–2016
State v. DeJesus green
conn · 2008
2 sentences

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

2016See, e.g., Mueller v. Tepler, 312 Conn. 631 , 647, 655, 95 A.3d 1011 (2014) (in limiting rule in Gurliacci v. Mayer, 218 Conn. 531 , 590 A.2d 914 [1991], Chief Justice Rogers reasoned "that allowing a plaintiff to maintain a loss of consortium claim under ... circumstances [in which she was not married to the injured person because such marriage was prohibited by law would] not impair preexisting expectations or reliance interests in any serious way"); State v. DeJesus, 288 Conn. 418 , 479 n. 2, 953 A.2d 45 (2008) ( Palmer, J., concurring) (reasoning that lack of "any material reliance" on pre

12016–2016
Charron v. Amaral green
mass · 2008
12014–2014
Kerrigan v. Commissioner of Public Health green
conn · 2008
12014–2014
Cruz v. Montanez green
conn · 2009
12011–2011
LITTLE v. Jarvis green
pasuperct · 1971
12011–2011
Ekalo v. Constructive Serv. Corp. of America green
nj · 1965
12011–2011
Norris v. Atlanta & West Point Railroad green
gactapp · 1985
12011–2011
Deems v. Western Maryland Railway Co. green
md · 1967
12011–2011
Manzitti v. Amsler green
pa · 1988
12011–2011
Rodriguez v. Bethlehem Steel Corp. green
cal · 1974
12011–2011
Oldani v. Lieberman green
michctapp · 1985
12011–2011
Yates v. State green
indctapp · 1982
12011–2011
Kibble v. Weeks Dredging & Construction Co. green
nj · 1999
12011–2011
Diaz v. Eli Lilly & Co. green
mass · 1973
12011–2011
Conradt v. Four Star Promotions, Inc. green
washctapp · 1986
12011–2011
State v. St. Onge neutral
me · 2011
12011–2011
Pugh v. Super Fresh Food Markets, Inc. green
paed · 1986
12011–2011
Stone Mountain Memorial Ass'n v. Herrington green
ga · 1969
12011–2011
Norris v. Atlanta & West Point Railroad green
ga · 1985
12011–2011
Hall v. Gardens Services, Inc. green
gactapp · 1985
12011–2011
Guttman Oil Co. v. Pennsylvania Insurance Guaranty Ass'n green
pasuperct · 1993
12006–2006
Casey v. Pohlman green
illappct · 1990
12001–2001
Wei Ping Wu v. Town of Fairfield green
conn · 1987
12001–2001

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 52-555 (3) CT § Conn. Gen. Stat. § 52-572m (3) CT § Conn. Gen. Stat. § 52-584 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CT 71 (1979–2025) LA 69 (1988–2023) OH 66 (1983–2025) IL 52 (1983–2025) CA 51 (1988–2025) PA 49 (1986–2026) GA 45 (1983–2025) TX 36 (1991–2022) MA 29 (1980–2023) FL 29 (1988–2024) MI 28 (1978–2026) IN 26 (1982–2020) MO 22 (1974–2021) NM 21 (1996–2025) WA 21 (1987–2021) MS 21 (1990–2024) IA 21 (1981–2024) NY 19 (1983–2024) ME 19 (1978–2020) NJ 14 (1982–2019) TN 14 (1997–2026) MD 14 (1984–2014) AL 12 (1986–2015) RI 12 (1992–2026) CO 12 (1986–2011) MN 12 (1981–2026) AZ 11 (1985–2026) SC 10 (1986–2025) KY 9 (1980–2025) VT 9 (1987–2026) SD 8 (1994–2007) HI 7 (1983–2024) DC 7 (1997–2025) DE 7 (1988–2025) NC 7 (1999–2022) WI 5 (1986–2020) AK 5 (1975–2020) MT 5 (1987–2014) WV 5 (1993–2013) OR 4 (1993–2021) ID 4 (1985–2025) UT 3 (2002–2018) NH 2 (1985–1987) NV 2 (1996–2023) NE 2 (2006–2013) AR 2 (2003–2003) ND 2 (1992–2015) WY 2 (2002–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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