LOSS OF CONSORTIUM CLAIMS (SUBROGATION)

In Bridges v Van Enterprises d/b/a/ Reliable Chevrolet, 992 S.W.2d 322 (Mo.App. S.D. 1999), a widow’s claim for loss of consortium prior t the employee’s death was independent of claims under the wrongful death statute, precluding an employer from exercising subrogation rights as to the pre-death claim.