Section 920, comment d; see also Section 920, comment a (stating that “[t]he rule stated in this Section normally requires that the damages allowable for an interference with a particular interest be diminished by the amount to which the same interest has been benefitted by the defendant’s tortious conduct”). Other jurisdictions have rejected the application of Section 920 in wrongful birth cases, see, e.g., Taylor v. Kurapati, 236 Mich.App. 315, 600 N.W.2d 670, 674-91 (1999) (abrogating the wrongful birth cause of action and commenting, in dicta, as to the inapplicability of the benefit rule); Bader v. Johnson, 675 N.E.2d 1119, 1123 (Ind.Ct.App.1997), while others have permitted an offset for emotional benefits, see, e.g., Phillips v. U.S., 575 F.Supp. 1309, 1319-20 (D.S.C.1983) (<HOLDING>); Harbeson v. Parke-Davis, Inc., 98 Wash.2d
holding that the emotional benefits to the parents resulting from the childs birth could be applied to offset any damage award recognizing the unique relationship between mother and child during pregnancy and birth and permitting mothers claim for emotional distress where the mothers emotional wellbeing and the birth of the child are inextricably intertwined holding that courts may look to parental conduct both before and after childs birth to determine whether termination is appropriate that parents conduct need not be directed at child and that danger to childs wellbeing may be inferred from parental misconduct standing alone holding that there was no evidence or inferences to be drawn from the evidence to support the damage award holding that to offset a jurys damage award a separate thirdparty insurance award must cover the same loss which served as the basis for the jury award