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Sorrells v. M.Y.B. Hospitality Ventures of Asheville10/8/1993
e parties for the same loss.
This approach is not without precedent in North Carolina law. In Nicholson v. Hospital, 300 N.C. 295, 266 S.E.2d 818 (1980), this Court held that
a spouse may maintain a cause of action for loss of consortium due to the negligent actions of third parties so long as that action for loss of consortium is joined with any suit the other spouse may have instituted to recover for his or her personal injuries.
Id. at 304, 266 S.E.2d at 823. A claim of negligent infliction of emotional distress flowing from an injury to a third party bears sufficient resemblance in all pertinent respects to a claim for loss of consortium to merit requiring the two claims to be joined in the same action. See Ruark, 327 N.C. at 314-15, 395 S.E.2d at 103 (Meyer, J., Dissenting).
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