Eric Liff, as Executors of the Estate of Joseph Liff v. Herman Schildkrout, Respondent Ronald Grant, as…

Summary

The Court held that a surviving spouse may not maintain a common‑law loss‑of‑consortium action arising from a decedent’s death, that loss of consortium is not a recoverable element of damages in a wrongful‑death action, and that the two‑year statute of limitations applies to such claims. Accordingly, it affirmed the Appellate Division’s orders in Liff and Grant and reversed the Appellate Division in Ventura.