This was an action by the administrator under the survival act. Decedent's mother while a passenger on the defendant's street-car was injured through negligence of an employee. Decedent thus suffered prenatal injuries to his skull from which he died three months after birth. The birth occurred 22 days after the accident and after a normal period of gestation. Held, there is no liability to an infant for prenatal injuries and therefore no cause of action existed in the child or survives to the administrator. Newman v. City of Detroit, 281 Mich. 60, 274 N. W. 710 (1937).
Frank B. Stone,
TORTS - PRENATAL INJURIES TO INFANTS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol36/iss3/26