In wrongful death cases generally the surviving spouse is limited to damages for a loss of consortium. In Washington loss of consortium means: “…the fellowship of husband and wife and the right of one spouse to the company, cooperation, and aid of the other in the matrimonial relationship. It includes emotional support, love, affection, care, services, companionship, including sexual companionship, as well as assistance from one spouse to the other.” Washington Pattern Jury Instruction WPI 32.04.

However, new medical research has found that people are more likely to develop an irregular heartbeat following the death of their spouse or life partner, particularly if they are younger or the loved one died unexpectedly.

The Study found that risk of atrial fibrillation—an irregular heartbeat that can cause stroke and heart disease—was 41 percent higher among people mourning the death of their partner, compared to others who are not grieving. In other words, people who unexpectedly lose their spouse are more likely to develop an irregular heartbeat that can cause death. The full text of this study can be found here:

[Long-term risk of atrial fibrillation after the death of a partner](http://openheart.bmj.com/content/3/1/e000367.full)

This research found that the unexpected death of a spouse—which is what happens in most wrongful death cases—can cause physical injury to the surviving spouses. Indeed, according to this literature there is a very real possibility a surviving spouse can die of a broken heart.
In the future the law may need to evolve to recognize a surviving spouse’s claim for physical injury, in addition to their existing claim for loss of consortium damages.