Bullard v. Barnes

In Bullard v. Barnes, 102 Ill. 2d 505, 468 N.E.2d 1228, 82 Ill. Dec. 448 (Ill. 1984), the court held that parents are entitled to a presumption of pecuniary injury from the loss of a deceased child's society and companionship in a wrongful death action. Although damages recoverable under the Illinois Wrongful Death Act were expanded in Bullard to include loss of consortium, juries were forced to make their decisions by disregarding any consideration of the impact the death had on survivors emotionally.