Lieding v. Commercial Diving Center

In Lieding v. Commercial Diving Center (1983) 143 Cal. App. 3d 72, a man was injured in a diving accident a month and a half before his wedding. Following the wedding, he sued the diving companies, and his wife brought a claim for loss of consortium. Division One of the Second Appellate District concluded the trial court had properly granted summary judgment against the woman on her claim. Quoting with approval a decision of the Supreme Judicial Court of Maine, the court wrote: " 'The general rule is that no person has a right of action against a wrongdoer, unless that person is personally injured. The cause of action accrues, generally, when the tort is committed. When the alleged antenuptial tort was committed by the defendant against the woman plaintiff, the man plaintiff suffered no injury, because he possessed no marital right at that time, never having assumed any marital obligations.' " ( Id. at p. 75.)