loss of consortium claim (South Dakota) · Go Syfert
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loss of consortium claim in South Dakota

8 South Dakota opinions name it 1 courts 1994–2007 0 in the last five years

The cases below were cited by South Dakota 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 (7)

CaseFollowedCited
Callies v. Reliance Laundry Co.green
wis · 1925 · cited in 3 South Dakota opinions naming this issue, 1996–1996
2 sentences

1996In Bar-ger, we cited with approval the language of Callies v. Reliance Laundry Co., 188 Wis. 376 , 206 N.W. 198, 200 (1925), where it was stated: The parent is by law required to support and care for his child.

1996In Bar-ger, we cited with approval the language of Callies v. Reliance Laundry Co., 188 Wis. 376 , 206 N.W. 198, 200 (1925), where it was stated: The parent is by law required to support and care for his child.

33
Miller v. Hernandezgreen
sd · 1994 · cited in 1 South Dakota opinions naming this issue, 2000–2000
1 sentence

2000Compare Miller, 520 N.W.2d at 271 (noting that the court and parties agreed to use a special interrogatory to determine how to calculate prejudgment interest, but failed to do so). [¶ 44.] Although special interrogatories would have been helpful to appellate review in this case, the jury instructions and the general verdict form were correct, even though general, and the real problem appears to be lack of proof rather than lack of specificity.

11
Page v. Hibbardgreen
ill · 1987 · cited in 1 South Dakota opinions naming this issue, 1998–1998
2 sentences

1998Page v. Hibbard, 119 Ill.2d 41 , 115 Ill.Dec. 544, 547 , 518 N.E.2d 69, 72 (1987). 3 [¶ 13.] Zoss cites Dionne v. Libbey-Owens Ford Co., 621 A.2d 414, 417-18 (Me.1993), for the same proposition but also argues that the burden was on Insurer to ferret out evidence of like damages; however, two years after Dionne , the Maine Supreme Court ruled that the burden is on the employee or spouse to either obtain an express allocation in the settlement or a judicial determination of the loss of consortium claim.

1998Page v. Hibbard, 119 Ill.2d 41 , 115 Ill.Dec. 544, 547 , 518 N.E.2d 69, 72 (1987). 3 [¶ 13.] Zoss cites Dionne v. Libbey-Owens Ford Co., 621 A.2d 414, 417-18 (Me.1993), for the same proposition but also argues that the burden was on Insurer to ferret out evidence of like damages; however, two years after Dionne , the Maine Supreme Court ruled that the burden is on the employee or spouse to either obtain an express allocation in the settlement or a judicial determination of the loss of consortium claim.

11
Nichols v. Cantara & Sonsgreen
me · 1995 · cited in 1 South Dakota opinions naming this issue, 1998–1998
1 sentence

1998See Nichols v. Cantara & Sons, 659 A.2d 258, 259-61 (Me.1995).

11
Dionne v. Libbey-Owens Ford Co.green
me · 1993 · cited in 1 South Dakota opinions naming this issue, 1998–1998
1 sentence

1998Page v. Hibbard, 119 Ill.2d 41 , 115 Ill.Dec. 544, 547 , 518 N.E.2d 69, 72 (1987). 3 [¶ 13.] Zoss cites Dionne v. Libbey-Owens Ford Co., 621 A.2d 414, 417-18 (Me.1993), for the same proposition but also argues that the burden was on Insurer to ferret out evidence of like damages; however, two years after Dionne , the Maine Supreme Court ruled that the burden is on the employee or spouse to either obtain an express allocation in the settlement or a judicial determination of the loss of consortium claim.

11
Freer v. Hysan Corporationgreen
ill · 1985 · cited in 1 South Dakota opinions naming this issue, 1998–1998
2 sentences

1998During this time, Insurer will cease the monthly payments. (7) After the number of months of payments provided for in (6) have elapsed, Insurer will continue to pay Zoss her monthly benefit amount, not subject to any lien. 7 *264 Accord Denius v. Robertson, 98 Ill.App.3d 83 , 53 Ill.Dec. 701, 704-05 , 424 N.E.2d 336, 339-40 (1981); see also Freer v. Hysan Corp., 108 Ill.2d 421 , 92 Ill.Dec. 221, 225 , 484 N.E.2d 1076, 1080 (1985) (“[T]he suspension of payments is the most expedient and accurate method for protecting the employer’s rights.”). [¶ 18.] The order granting summary judgment to Zoss

1998During this time, Insurer will cease the monthly payments. (7) After the number of months of payments provided for in (6) have elapsed, Insurer will continue to pay Zoss her monthly benefit amount, not subject to any lien. 7 *264 Accord Denius v. Robertson, 98 Ill.App.3d 83 , 53 Ill.Dec. 701, 704-05 , 424 N.E.2d 336, 339-40 (1981); see also Freer v. Hysan Corp., 108 Ill.2d 421 , 92 Ill.Dec. 221, 225 , 484 N.E.2d 1076, 1080 (1985) (“[T]he suspension of payments is the most expedient and accurate method for protecting the employer’s rights.”). [¶ 18.] The order granting summary judgment to Zoss

11
Denius v. Robertsongreen
illappct · 1981 · cited in 1 South Dakota opinions naming this issue, 1998–1998
2 sentences

1998During this time, Insurer will cease the monthly payments. (7) After the number of months of payments provided for in (6) have elapsed, Insurer will continue to pay Zoss her monthly benefit amount, not subject to any lien. 7 *264 Accord Denius v. Robertson, 98 Ill.App.3d 83 , 53 Ill.Dec. 701, 704-05 , 424 N.E.2d 336, 339-40 (1981); see also Freer v. Hysan Corp., 108 Ill.2d 421 , 92 Ill.Dec. 221, 225 , 484 N.E.2d 1076, 1080 (1985) (“[T]he suspension of payments is the most expedient and accurate method for protecting the employer’s rights.”). [¶ 18.] The order granting summary judgment to Zoss

1998During this time, Insurer will cease the monthly payments. (7) After the number of months of payments provided for in (6) have elapsed, Insurer will continue to pay Zoss her monthly benefit amount, not subject to any lien. 7 *264 Accord Denius v. Robertson, 98 Ill.App.3d 83 , 53 Ill.Dec. 701, 704-05 , 424 N.E.2d 336, 339-40 (1981); see also Freer v. Hysan Corp., 108 Ill.2d 421 , 92 Ill.Dec. 221, 225 , 484 N.E.2d 1076, 1080 (1985) (“[T]he suspension of payments is the most expedient and accurate method for protecting the employer’s rights.”). [¶ 18.] The order granting summary judgment to Zoss

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Shiels v. Audette green
conn · 1934
1 sentence

2007Id. (analogizing with Titze v. Miller, 337 N.W.2d 176 (S.D.1983) (holding that a husband’s cause of action for loss of consortium failed when the injured spouse was unable to recover damages for her own personal injuries, because although separate and distinct from the injured spouse’s claim for personal injuries, the loss of consortium claim was in any case derivative in nature)). [¶ 17.] This was precisely the basis upon which we answered question four in Knowles .

12007–2007
Titze v. Miller green
sd · 1983
1 sentence

2007Id. (analogizing with Titze v. Miller, 337 N.W.2d 176 (S.D.1983) (holding that a husband’s cause of action for loss of consortium failed when the injured spouse was unable to recover damages for her own personal injuries, because although separate and distinct from the injured spouse’s claim for personal injuries, the loss of consortium claim was in any case derivative in nature)). [¶ 17.] This was precisely the basis upon which we answered question four in Knowles .

12007–2007
Zoss v. Dakota Truck Underwriters green
sd · 1998
2 sentences

1999Zoss-1, 1998 SD 23, ¶ 17 , 575 N.W.2d at 263 . [¶ 11.] On remand, the trial court determined that Zoss had no viable loss of consortium claim.

1999Zoss-1, 1998 SD 23, ¶ 17 , 575 N.W.2d at 263 . [¶ 11.] On remand, the trial court determined that Zoss had no viable loss of consortium claim.

11999–1999
Lepic Ex Rel. Lepic v. Iowa Mutual Insurance Co. green
iowa · 1987
2 sentences

1994The insurer argued that the phrase, “for all damages for bodily injury sustained by any one person in any one accident” was not ambiguous, thus limiting liability under the policy to “one person” coverage and not allowing recovery of a loss of consortium claim. 402 N.W.2d at 761-63 .

1994The insurer argued that the phrase, "for all damages for bodily injury sustained by any one person in any one accident" was not ambiguous, thus limiting liability under the policy to "one person" coverage and not allowing recovery of a loss of consortium claim. 402 N.W.2d at 761-63 .

11994–1994

Statutes the citing opinions construe

SD § S.D. Codified Laws § 21-3-11 (4) SD § S.D. Codified Laws § 15-6-38 (3) SD § S.D. Codified Laws § 20-9-1 (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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