San Diego Law Review

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This Comment presents the case for Jodie Lynn Souter's claim for loss of consortium in a wrongful death action when her mother was killed in a car accident, and for the claims of all children deprived of their parents consortium by another's negligence. It takes the position that statute, precedent, and tort principles compel the recognition of such an action where, in the words of the Suter Court of Appeal, "there can be little question of the reality of the loss suffered by a child deprived of the society and care of its parent."

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