Plaintiff sued for loss of her right of consortium occasioned by the illness and death of her husband as a result of a sale of liquor by defendant in violation of a state statute. Defendant demurred on the ground that there was no cause of action granted by the statute for damages flowing from such an illegal sale. Held, an action for injury to the wife's right of consortium was available at common law. Swanson v. Ball, (S. D. 1940) 290 N. W. 482.
William C. Whitehead,
HUSBAND AND WIFE-WIFE'S RIGHT TO RECOVER FOR LOSS OF "CONSORTIUM" DUE TO INJURY TO HUSBAND FROM WRONGFUL SALE OF LIQUOR,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol39/iss5/12