Mass. Gen. Laws » Part III Title II Chapter 231
Massachusetts General Laws

Mass. Gen. Laws ch. 231, § 85X (2026)

Loss of consortium of a dependent child; cause of action

✓ current as of July 2026
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Section 85X. The parents of a minor child or an adult child who is dependent on his parents for support shall have a cause of action for loss of consortium of the child who has been seriously injured against any person who is legally responsible for causing such injury.

Notes of Decisions
Cited in 44 cases (5 in the last 5 years), 1990–2024 · leading case: Leibovich v. Antonellis, 574 N.E.2d 978 (Mass. 1991).
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Leibovich v. Antonellis, 574 N.E.2d 978 (Mass. 1991). · cites it 13× “In addition, we conclude that the defendant’s constitutional rights to due process were not violated by the retroactive application to this case of G. L. c. 231, § 85X (1990 ed.), the loss of filial consortium statute.”
Thomas v. Town of Chelmsford, 267 F. Supp. 3d 279 (D. Mass. 2017). · cites it 3× “Mass. Gen. Laws ch. 231, § 85X.. Consortium claims are derivative in nature, so it requires an underlying tortious act.”
St. Germaine v. Pendergast, 584 N.E.2d 611 (Mass. 1992). · cites it 6× “Germaines), sought in the action to recover for the loss of filial consortium of their son pursuant to G. L. c. 231, § 85X (1990 ed.), from Pendergast and his employer, Lacey & Lacey.”
Roberts v. Williamson, 111 S.W.3d 113 (Tex. 2003). · cites it 2× “See Mass. Gen. Laws ch. 231, § 85X; Monahan v.”
Ford Motor Co. v. Miles, 967 S.W.2d 377 (Tex. 1998). · cites it 2× “2d 951 (1990) (recognizing that Mass. Gen. Laws ch. 231, § 85X (1988) allows for recovery for loss of consortium); First Trust Co.”
Bobick v. United States Fid. & Guar. Co., 790 N.E.2d 653 (Mass. 2003). “18 The loss of filial consortium statute, G. L. c. 231, § 85X, inserted by St. 1989, c.”
Monahan v. Town of Methuen, 558 N.E.2d 951 (Mass. 1990). · cites it 2× “The town argues that under G. L. c. 231, § 85X (1988 ed.), the parents may not recover for loss of consortium.”
Gallimore v. Child.'s Hosp. Med. Ctr., 617 N.E.2d 1052 (Ohio 1993). “The Massachusetts legislature, for example, responded to a Massachusetts Supreme Judicial Court ruling that parents could not seek damages for loss of filial consortium by enacting a statute specifically allowing such a cause of action.”
Eyssi v. City of Lawrence, 618 N.E.2d 1358 (Mass. 1993). · cites it 2× “7 As to the statutory rights of parents for loss of consortium of their children, see G. L. c. 231, § 85X (1992 ed.). See also Monahan v.”
Reckis v. Johnson & Johnson, 28 N.E.3d 445 (Mass. 2015). “” G. L. c. 231, § 85X. 49 Finally, we find unavailing the defendants’ argument that the size of the jury’s award indicates that their purpose was to punish the defendants rather than to fairly compensate the plaintiffs.”
Burke v. Rivo, 551 N.E.2d 1 (Mass. 1990). · cites it 2× “" Post at 774 (O'Connor, J., dissenting). The process is not an unacceptably difficult one.”
Benoit v. Frederickson, 908 N.E.2d 714 (Mass. 2009). “ms for the acts of sexual assault, rape, assault and battery, intentional infliction of emotional distress, and false imprisonment that she alleged to have occurred between 1991 and July, 2002; she also asserted a claim for defamation; Frederickson as well as her parents…”
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