Keaton v. Ribbeck

58 Ohio St.2d 443, 391 N.E.2d 307 (1979)

Keaton was a passenger in a car driven by Ribbeck. Ribbeck crashed the car into a moving freight train, and Keaton died. Keaton’s parents brought a wrongful death action against Ribbeck, seeking recovery for the loss of society, comfort and companionship of their son.

The court denied this recovery, holding that there can be no recovery for loss of society, comfort and companionship of the decedent in a wrongful death action. (*The harsh outcome of this and other like cases finally motivated the Ohio Legislature to expand the elements of recovery to include loss of society, comfort, companionship and mental anguish.)