Loss of consortium.

Practice point: The cause of action does not lie if the alleged tortious conduct and resultant injuries occurred prior to the marriage.

Student note: Although New York does not itself recognize common-law marriages, a common-law marriage contracted in another State will be recognized as valid here if it is valid where contracted.

Case: Holmes v. Maimonides Medical Med. Ctr., NY Slip Op 03410 (2d Dept. 2012).

Here is the decision.

Tomorrow’s issue: A civilian complainant’s liability for false arrest.