O'Keefe v. Associated Grocers of New England, Inc.

On August 9, 1974, the plaintiff’s husband suffered work-related nonfatal injuries for which he received workmen’s compensation benefits pursuant to RSA chapter 281. The plaintiff brought this action for loss of consortium. RSA 507:8-a. The defendant moved to dismiss on the ground that the suit is barred by RSA 281:12 (Supp. 1975) which states in relevant part that “[t] he spouse of an employee entitled to benefits under this chapter shall have no direct right of action against the employer, or the employer’s insurance carrier, to recover for consequential damages.” The Trial Court (Keller,…