Wachocki v. Bernalillo County Sheriff’s Dept.

This appeal involved a loss-of-consortium claim brought by Plaintiff Bill Wachocki (Bill), the adult brother of Jason Wachocki (Jason). Twenty-two-year-old Jason was killed when his vehicle was struck by a speeding van driven by Willie Hiley (Willie), a corrections officer at the Metropolitan Detention Center. Bill argued his loss- of-consortium claim was "improperly foreclosed" by the application of the “mutual dependence” standard which was originally developed for spousal-type relationships. Upon review, the Supreme Court clarified that recovery for loss of consortium may extend to sibling relationships; however, the facts presented in this case did not exhibit the mutual dependence required for recovery. The Court affirmed the appellate court's conclusion.