John G. Voris v. Peter M. Molinaro

Summary

The court held that a loss-of-consortium claim is barred when the directly injured spouse settles the underlying negligence claim. It treated the rule previously stated in its precedent, and consistently applied in later decisions, as binding law because consortium claims are derivative and must be resolved with the predicate injury claim to avoid overlapping damages, inconsistent outcomes, and repeated litigation. Justice Palmer, dissenting, would have allowed the claim to proceed because the defendant knew of it before settling the wife's claims and the settlement did not release the plaintiff's claim.