Wohlfert v. Kresge

In Wohlfert v. Kresge, 120 Mich App 178, 180; 327 NW2d 427 (1982), the plaintiff was the personal representative of the estate of an individual who died as the result of an automobile accident. The jury found defendants negligent and returned a verdict for damages in the amount of $ 100,000. The plaintiff accepted payment on this verdict and executed a satisfaction of judgment. Subsequently, the plaintiff claimed on appeal that the court erred in failing to instruct the jury that the siblings of the deceased could be awarded damages for loss of society and companionship. The Court found that the jury's verdict included compensation for "the breakup of the family unit," and held that any allowable cause of action for the siblings' loss of companionship would involve losses that could not be considered separate and distinct from those addressed by the jury's initial verdict. Wohlfert, supra at 181. The Court dismissed the plaintiff's appeal.