Jordan v. Baptist Three Rivers Hospital

Supreme Court of Tennessee, at Nashville
984 S.W.2d 593 (1999)

ELI5:

Rule of Law:

Under Tennessee's wrongful death statute, the pecuniary value of a deceased person's life includes damages for loss of spousal and parental consortium, which encompasses the loss of companionship, society, guidance, and affection.

Facts:

Martha P. Jordan is the surviving child of Mary Sue Douglas, the decedent.
Mary Sue Douglas died after receiving medical care.
Jordan, as administratrix of Douglas's estate, alleges that Douglas's death was caused by the negligence of Baptist Three Rivers Hospital and several doctors.
The underlying action brought by Jordan is for medical malpractice resulting in wrongful death.

Procedural Posture:

Martha P. Jordan, on behalf of the decedent's estate, filed a medical malpractice and wrongful death action against Baptist Three Rivers Hospital and several doctors in a Tennessee trial court.
The complaint sought damages for, among other things, loss of parental consortium.
The defendants filed a motion to strike the claim for consortium damages, arguing it was not permitted under Tennessee law.
The trial court granted the defendants' motion to strike the consortium claim.
The plaintiff was granted permission for an interlocutory appeal, but the intermediate Court of Appeals denied the application.
The Supreme Court of Tennessee granted the plaintiff's appeal to decide the issue of whether consortium damages are available in wrongful death actions.

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Issue:

Does the 'pecuniary value' of a deceased's life, as recoverable under Tennessee's wrongful death statute, Tenn. Code Ann. § 20-5-113, include damages for loss of spousal and parental consortium?

Opinions:

Majority - Holder, J.

Yes. The pecuniary value of a deceased's life under the wrongful death statute includes consortium damages. The court reasoned that Tennessee’s wrongful death statute, a hybrid of survival and wrongful death statutes, permits recovery for 'damages resulting to the parties for whose use and benefit the right of action survives.' This language is broad enough to encompass non-economic losses. The court found it illogical and absurd to permit recovery for loss of consortium in personal injury cases where the victim survives, but not in wrongful death cases. Overturning its 1903 precedent in Davidson Benedict Co. v. Severson, the court redefined the 'pecuniary value' of a life to include the substantial and ascertainable value of human companionship, society, protection, and affection for both spouses and children, including adult children.

Analysis:

This decision significantly expands the scope of recoverable damages in Tennessee wrongful death actions by overturning nearly a century of precedent. By reinterpreting the statutory term 'pecuniary value' to include non-economic, relational losses, the court aligned Tennessee with the modern trend in other jurisdictions. This holding substantially increases the potential value of wrongful death claims, requiring juries to quantify intangible losses like companionship and guidance. It will impact litigation strategy and settlement negotiations in all future wrongful death cases in the state, particularly those involving decedents with close family relationships.

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