Plaintiff sued for loss of the opportunity to bear children by her husband resulting from his emasculation caused by defendant's negligence. The court below dismissed the complaint. Held (one judge dissenting), judgment affirmed. Such a cause of action has never been recognized. It cannot be said that the wrong is the proximate cause of the loss because of the many elements of doubt and conjecture in connection with the birth of children. Landwehr v. Barbas, 24I App. Div. 769, 270 N. Y. S. 534 (I934).
DOMESTIC RELATIONS-RIGHT OF WIFE TO CONSORTIUM-NEGLIGENT INJURY TO HUSBAND,
Mich. L. Rev.
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