About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline



Case Citations [i] (Spring 2026)

handle is hein.ali/rtotelwtd0007 and id is 1 raw text is: 





                            THE AMERICAN


                              LAW INSTITUTE



                                    Spring 2026 Citations



    TORTS 3D: MISCELLANEOUS PROVISIONS

                                    (DRAFTS)



                  LIABILITY   FOR  PHYSICAL AND EMOTIONAL HARM

                    CHAPTER 8.   LIABILITY   FOR   EMOTIONAL HARM

§ 48 A. Loss of Spousal Consortium

Conn.2025. Com.  (g) cit. in ftn. (citing com. (g) of T.D. No. 1, 2022). After infant child was severely
injured when the car seat she was strapped into was placed next to an electric stove and caught fire,
child's parents filed claims for, among other things, loss of filial consortium against manufacturer and
retailer of the car seat and stove in federal court, alleging that the fire was caused by the faulty design or
production of both the car seat and stove. Answering a question certified by the federal court, this court
held that Connecticut did not recognize a parent's claim for loss of filial consortium in a child who
suffered severe, but nonfatal, injuries because of a defendant's tortious conduct. The dissent cited
Restatement Third of Torts: Concluding Provisions § 48 A, Comment g, in arguing that numerous
jurisdictions allowed for statutory or common-law causes of action for loss of filial consortium. L.L. v.
Newell Brands, Inc., 330 A.3d 53, 70.

§ 48 B. Loss of Child Consortium

Conn.2025. Com.  (b) cit. but not. fol. and cit. in diss. op., Rptr's Note to com. (b) quot. in diss. op.
(T.D. No. 1, 2022). After infant child was severely injured when the car seat she was strapped into was
placed next to an electric stove and caught fire, child's parents filed claims for, among other things, loss
of filial consortium against manufacturer and retailer of the car seat and stove in federal court, alleging
that the fire was caused by the faulty design or production of both the car seat and stove. Answering a
question certified by the federal court, this court held that Connecticut did not recognize a parent's claim
for loss of filial consortium in a child who suffered severe, but nonfatal, injuries because of a
defendant's tortious conduct. The dissent cited Restatement Third of Torts: Concluding Provisions § 48
B, which recognized a cause of action for loss of filial consortium, in arguing that the trend was towards
recognition of such claims. L.L. v. Newell Brands, Inc., 330 A.3d 53, 59, 70.

                           COPYRIGHT C2026 By THE AMERICAN LAW INSTITUTE
                                        All rights reserved
                                  Printed in the United States of America
          For earlier citations, see the Appendices, Supplements, or Pocket Parts, if any, that correspond to the subject matter under examination.