In the case of Young v. Est. of Young, No. 658 C.D. 2015 (Cmwlth. Ct. April 12, 2016 Simpson, Wojcik, Pellegrini, J.J.)(Op. by Simpson, J.), the Pennsylvania Commonwealth Court sustained preliminary objections to a Complaint and ruled, in pertinent part, that there is no cause of action recognized in Pennsylvania for a nephew's loss of an aunt's or uncle's consortium based upon alleged mistreatment by third parties during the elderly aunt's and uncle's final days.
The strange facts of this case can be read online HERE.