Case Law Update: Wrongful Death not allowed for In Vitro Fertilization
Miller v. American Infertility Group of Illinois, S. C, No. 1-05-3202 (10/24/08) stated that Section 2.2 of Wrongful Death Act, does not allow recovery for wrongful death for the loss of a fertilized embryo, created through in vitro fertilization, that has not been implanted into the mother. This Illinois Appellate Case will have a great impact on wrongful death lawsuits when discussing in vitro fertilization.

