Steele v. Botticello
Annotate this CaseEryn Steele was married to Chris Steele when Ryan Botticello allegedly assaulted Chris. Chris sued Ryan and his father for damages related to his injuries and later settled and released his claim against the Botticellos. Later, Eryn sued the Botticellos for damages related to her loss of consortium. The Botticellos asserted the affirmative defense of release in their amended answer and moved for summary judgment. The trial court entered summary judgment in favor of the Botticellos, concluding that, under Brown v. Crown Equipment Corp., Chris's release barred Eryn's consortium claim because it was derivative of Chris's underlying tort claim. The Supreme Court vacated the judgment of summary judgment, holding that an injured person's settlement and release of a claim for personal injuries does not preclude that person's spouse from recovering for loss of consortium when the spouse was not a party to the settlement and release. Remanded.
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