Loss of Consortium Language for a Complaint

Note: This is for lawyers looking to properly plead a loss of consortium count in a personal injury lawsuit. A huge word of caution. In the wrong case, a loss of consortum claim can absolutely destroy a personal injury case. So look where you leap.


The Plaintiffs incorporate by reference all the above paragraphs as though fully set forth herein.

  1. At the time of the accident complained of in the Plaintiffs' Complaint, the Plaintiffs were married and that the Plaintiffs continue to be married.
  2. That as a result of the wrongful and negligent acts of the Defendants, and each of them, the Plaintiffs were caused to suffer, and will continue to suffer in the future, loss of consortium, loss of society, affection, assistance, and conjugal fellowship, all to the detriment of their marital relationship.
  3. That all the aforesaid injuries and damages were caused solely and proximately by the negligence of the Defendants.

WHEREFORE, the Plaintiffs jointly as husband and wife, demand judgment against the Defendants, jointly and severally, in the amount of SIX HUNDRED FIFTY THOUSAND DOLLARS ($650,000.00), plus costs, prejudgment interest, post judgment interest, and any other costs this court deems appropriate.

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