The Illinois Supreme Court upheld a $2.1 million jury verdict in case against a doctor who was accused of causing the death of a patient by not treating her blood clot properly. The woman passed away at 34 and her husband sought damages, including damages for the loss of her material services, which include her contributions to household income and home-keeping.

The main issue was whether her husband could claim these types of damages since he remarried about 13 months after her death. The court ruled that his remarriage did not negate his right to recover for material services, distinguishing this claim from loss of consortium, which in Illinois, typically ends with remarriage. The justices reaffirmed that plaintiffs could seek compensation for material services in wrongful death cases, regardless of subsequent marital status.

This resulted in the original verdict to be maintained, though it was slightly reduced to $1.7 million due to a finding of partial fault on the part of the deceased.