LeFiell Mfg. Co. v. Superior Court, 2012 WL 3570743 (Cal. S. Ct. 2012)

O'Neil Watrous and his wife Nidia filed a civil action against LeFiell Manufacturing for injuries O'Neil suffered while he was operating a swaging machine at work. The swaging machine is a "power press machine" within the meaning of Cal. Labor Code § 4558 – an injury from which provides an exception to the workers' compensation exclusivity rule that usually applies to industrial injuries. In addition to O'Neil's claims, Nidia asserted a claim for loss of consortium. The Supreme Court held that Nidia's loss of consortium claim should have been dismissed on demurrer by the trial court because "where, as here, the worker's power press injuries do not prove fatal, the Legislature has expressly restricted standing to bring the action at law… to the injured worker alone [and not his spouse]."