Abstract
Comment: Torts
In Frank v. Superior Court, the Arizona Supreme Court held that parents have a cause of action for loss of consortium when their adult child is injured by a negligent third party. To date, no other jurisdiction has allowed recovery for lost consortium of an injured adult child. Indeed, only a handful of jurisdictions allow recovery for loss of consortium at all. Nevertheless, the Frank decision marks the continuation of a logical progression of case law in Arizona. This progression should stand as an example to those jurisdictions that continue to rely upon outdated theories which preclude recovery for loss of filial consortium. This Comment traces the Arizona case law preceding Frank and examines the Frank decision. It then discusses the effect this decision may have on other relationships in claims for loss of consortium.
How to Cite
29 Ariz. L. Rev. 541 (1987)
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