DeWitt v. B & C Machine Co.

The issue presented is whether a wife has an independent action for the loss of her husband’s consortium against a person whose negligence caused her husband’s instantaneous death.

In Clouston v. Remlinger Oldsmobile Cadillac, Inc., supra, we held that the negligent injury of a husband gives rise to a cause of action in favor of his wife for any loss of his consortium which directly and proximately results from such injury. While that decision equalized the rights of a husband and a wife to bring an action for loss of consortium, it did not affect the logical import of Shaweker v. Spinell…