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Domestic Partnerships and Wrongful Death Actions

In Langan v. St. Vincent’s Hosp. of New York, 802 N.Y.S.2d 476 (N.Y. App. Div. 2005), a divided court overruled the trial court and held that the survivor of a Vermont civil union may not maintain a wrongful death action on the same basis as a spouse because the Vermont civil union is not a “marriage.”

Special thanks to Rita and Joseph Solomon Prof. William P. LaPiana of the New York Law School for contributing this case.