Where the loss of her husband's consortium is the result of personal injuries caused by the mere negligence of a third person, the wife has no cause of action; she did not have such right at common law and no legislation has been enacted to give her this right. Nevertheless, at the same time that this right is denied to the wife, her husband has a cause of action under identical circumstances. In such a case, the gist of the action is the loss of his wife's services, and the right has not been affected by legislation which has abrogated the common law disabilities of the wife.
Note, Husband and Wife-Consortium Right of Action in Wife for Negligent Injury to Husband, 1 Clev.-Marshall L. Rev. 73 (1952)