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Salvati v Hicks; (WCC-UNP, 10/21/1976; RB #63)


Wayne County Circuit Court; Docket No. 76-612-456-NI; Unpublished    
Judge William J. Giovan; Written Opinion   
Official Michigan Reporter Citation: Not Applicable; Link to Opinion alt   

Loss of Consortium Claims [§3135]

Legislative Purpose and Intent   

In a written Opinion, Circuit Judge William Giovan held that the no-fault statute, and in particular §3135(1) and (2), bars claims for loss of consortium by spouses of injured persons who sustain "threshold injuries." The Court held that §3135(1) identifies the kinds of loss that will invoke residual liability for noneconomic loss and §3135(2) limits recovery for noneconomic loss to those very same elements that constitute the conditions of recovery. Since loss of consortium does not fall within any of the other classes of damages specified in §3135(2), there is no residual liability on the part of tortfeasors for that element of damage.

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