What is the test for limiting the class of potential plaintiffs in a personal injury action where there are no putative spouses?

The reasoning of the court in Elden v. Sheldon reinforces the propriety of limiting the class of potential plaintiffs. The court in Elden stated three reasons for denying recovery to putative spouses: first, the state has an interest in promoting lawful marriage; second, allowing such a cause of action would require "a court to inquire into the relationship of the partners to determine whether the 'emotional attachment of the family relationship' existed between the parties [citation], and whether the relationship was 'stable and significant' [citation]" (46 Cal.3d at pp. 275-276, 250 Cal.Rptr. 254, 758 P.2d 582); and, third, the need to limit the number of persons to whom a negligent respondent owes a duty of care. (Id. at pp. 274-277, 250 Cal.Rptr. 254, 758 P.2d 582.)