Helsel v. Noellsch

The common law consistently compensates for interference with the marriage *234relation — “loss of consortium.” Loss of consortium is the second of three elements in an alienation of affection claim. Gibson v. Frowein, 400 S.W.2d 418, 421 (Mo. banc 1966). “The foundation of a cause of action for alienation of affection is the loss of consortium.” Kraus v. Kraus, 693 S.W.2d 869, 873 (Mo.App.1985).

In tort cases where a spouse is injured, the other spouse often has a separate claim for loss of consortium. Powell v. American Motors Corp., 834 S.W.2d 184, 188 (Mo. banc 1992). Most of these losses are…