f limiting the liability of third parties until after a number of other states imposed liability, and then somewhat belatedly imposed expanded liability. Such a pattern has been developing in the parental consortium area.
In Taylor v. Keefe, 134 Conn. 158 (1947), the Connecticut Court held that no cause of action existed on behalf of a minor child for alienation of the affections of his mother. The facts of the case were that defendant's actions had led to the divorce of the child's father and mother, to the child's distress and to his being deprived of his mother's lovej and affection. The Court relied on the fact that the gist of an action for alienation of affection is the loss of marital consortium and that very few states extended such rights to children. It also pointed out that in marital consortium cases, the loss or diminution of a property right was involved but not in cases involving children's loss of parental consortium in which only legally unenforceable 'natural' rights and, therefore, no legal harm were involved. Finally, the Court pointed out that neighboring states such as Massachusetts and New York had done away with alienation of affection causes of action. Since the Goyette children's claim is based on negligence not on alienation of affections, this case is not directly in point. In Steeves v. Alexander Trucking Co., 14 Conn. L. Rptr. 167 (July 6, 1995), the Hartford-New Britain Superior Court said at 168 that "no appellate court in our state has explicitly decided whether there is an action for loss of parental . . . consortium." In one appellate case, Mahoney v. Lensink, 17 Conn.App. 130, 141 n. 7, 550 A.2d 1088, (reversed in part on other grounds) 213 Conn. 548, 569 A.2d 518 (1990), the court commented that the "right of consortium is said to arise out of the civil contract of marriage and as such, does not extend to the parent-child relationship." However, that statement in Mahoney was dicta because that c...