## Facts

- Mary Sue Douglas died following medical treatment involving Baptist Three Rivers Hospital and several physicians.
- Martha P. Jordan, as administratrix of Douglas’s estate and as a surviving child, brought a medical malpractice/wrongful death action alleging negligent care caused Douglas’s death.
- The complaint sought damages for (1) loss of consortium (spousal and parental) and (2) loss of enjoyment of life (hedonic damages).
- Defendants moved to strike the consortium and hedonic-damages allegations and sought judgment on the pleadings, arguing Tennessee law did not allow those elements in wrongful death actions.
- The trial court struck the consortium and hedonic-damages allegations and permitted an interlocutory appeal.
- The Court of Appeals denied the interlocutory appeal as untimely and, alternatively, as not appropriate.
- The Tennessee Supreme Court granted review to decide whether wrongful-death damages under Tenn. Code Ann. § 20-5-113 include consortium losses and whether hedonic damages are available as a separate element.

## Issues

1. Whether the “pecuniary value” of the decedent’s life recoverable under Tenn. Code Ann. § 20-5-113 includes survivors’ loss of consortium, including spousal and parental consortium.
2. Whether Tennessee law permits recovery of hedonic damages (the decedent’s loss of enjoyment of life) as a distinct element of damages in a wrongful death action.

## Decision

- The Tennessee Supreme Court held that loss of consortium is recoverable in wrongful death actions as part of the “pecuniary value” of the decedent’s life.
- The Court allowed both spousal and parental consortium as components of wrongful-death damages under the statute.
- The Court declined to recognize hedonic damages as an independent, separate category of wrongful-death damages.
- The Court reversed the trial court’s order striking the consortium claim, affirmed the rejection of a separate hedonic-damages claim, and remanded for further proceedings.

## Legal Principles

- Under Tenn. Code Ann. § 20-5-113, the “pecuniary value” of a decedent’s life is not limited to lost earnings and may include relational losses suffered by statutory beneficiaries.
- Loss of consortium is a compensable element within the “pecuniary value” of life in Tennessee wrongful death actions, including spousal and parental consortium.
- The Court did not decide whether a child may recover parental-consortium damages in a personal injury action when the parent survives.
- Tennessee does not recognize “loss of enjoyment of life” (hedonic damages) as a standalone wrongful-death damage element separate from the statutory measure of damages, in part to avoid duplicative recovery absent legislative authorization.

## Conclusion

The Tennessee Supreme Court interpreted the wrongful-death statute to permit recovery for spousal and parental loss of consortium as part of the pecuniary value of the decedent’s life, while rejecting hedonic damages as a separate, independently recoverable category in wrongful death cases.


Jordan v. Baptist Three Rivers Hosp., 984 S.W.2d 593 (Tenn. 1999)