With latent injury cases, injury often does not occur at the time of exposure to a toxic substance, but often decades later. The Court of Appeal held the required showing of the existence of a valid marriage for a loss of consortium claim is satisfied if the plaintiff’s marriage to the injured spouse predates discovery of symptoms or diagnosis. Vanhooser v. Sup. Ct. (Hennessy Industries, Inc.) (Cal. App. Second Dist., Div. 3; June 1, 2012) (Case No. B239677).