Brown v. Metzger

At issue in this case is whether an injured party’s release in settlement of a personal-injury action bars that party’s spouse from maintaining an independent cause of action for loss of consortium. The case arose out of an automobile accident on March 30, 1980, when a car in which Eldridge Brown was a passenger was struck by a vehicle driven by Patrick Metzger. In 1981 Eldridge Brown (the impaired spouse) filed an action against Metzger in Lake County circuit court to recover for the injuries he incurred in the accident, and his wife, Julia Brown (the deprived spouse), who is the plaintiff…