Kowalsky v. Leonard

This demurrer raises the question as to whether a father may recover from a tort-feasor for the loss of the services of his minor son resulting from the wrongful death of that son.

It is fundamental that, at common law no cause of action would lie in favor of anyone for wrongful death and this rule has been almost universally applied so as to deny to surviving husbands the right to recover for loss of consortium resulting from wrongful death of their wives and to surviving parents of children killed by the wrongful act the right to recover for loss of services after the death.

Schouler,…