# Krouse v. Graham

Canonical: https://californiapersonalinjurylaws.com/cases/krouse/

Supreme Court of California, 1977. 19 Cal.3d 59, pp. 67–72.

Reviewed by Andrew (Andy) R. Gillin; publisher reported approval 2026-11-04. The original review date was not supplied.

## Case background

A family sought damages after a car crash killed a wife and mother. The court reviewed what the jury had been told to include in damages.

## Question before the court

Which losses could the jury consider in the wrongful-death part of the case?

## What the court decided

Loss of companionship could be considered. Grief and mental distress could not simply be included as wrongful-death damages. The court found errors that required further proceedings.

## Limits

The case also discussed a separate emotional-harm claim. The rules for that claim need their own review.

## Opinion

https://law.justia.com/cases/california/supreme-court/3d/19/59.html