California, United States of America
The following excerpt is from Cheyanna M. v. A.C. Nielsen Co., 66 Cal.App.4th 855, 78 Cal.Rptr.2d 335 (Cal. App. 1998):
[66 Cal.App.4th 872] In Scott v. McPheeters (1939) 33 Cal.App.2d 629, 92 P.2d 678, the court was faced with the question of whether a child, once born, can maintain an action for personal injuries sustained in utero. In recognizing such a claim, the court discussed the "interests" protected by section 43.1:
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