Section 17 Grief and Bereavement Damages Not Recoverable

• Library: Damages 2012

Section 537.090, RSMo Supp. 2011, clearly states that “damages for grief and bereavement by reason of the death shall not be recoverable.” But because recovery is now allowed for loss of consortium, companionship, comfort, and other such nonpecuniary losses, the practical impact of this disclaimer is somewhat unclear. See §18.8, supra.

In Powell v. American Motors Corp., 834 S.W.2d 184 (Mo. banc 1992), the Court held that a cause of action for loss of consortium because of an injury may be brought by the...