What is the test for a lump sum verdict in a wrongful death action?

California, United States of America


The following excerpt is from Morales v. Superior Court, 160 Cal.Rptr. 194, 99 Cal.App.3d 283 (Cal. App. 1979):

1 A "lump sum" verdict is required though the total recovery is the aggregate of pecuniary loss of each of the heirs entitled to recover by reason of the death of the decedent (Perkins v. Robertson (1956) 140 Cal.App.2d 536, 543, 295 P.2d 972). Other nonpecuniary detriment to the future father-child relationship may occur.

2 We are not deciding whether such evidence Would be admissible at trial.

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