the extent of access thereto, operational condition of the vehicle, its proximity to surveillance, the time of day or night the vehicle is left unattended, and the length of time (and distance) elapsing from the theft to the accident. McClenahan v. Cooley, 806 S.W.2d 767, 776 (Tenn.1991) (alteration in original). 3. Loss of Consortium {36} Finally, although Plaintiffs concede that Alma Rosa De Ruiz, wife to the decedent, must withdraw her wrongful death claim because she is not the decedent’s personal representative, Plaintiffs contend that she has a viable loss of consortium claim based on a successful suit by Plaintiffs. This dependent claim would not fail if Plaintiffs successfully complete their wrongful death action. See Romero v. Byers, 117 N.M. 422, 426, 872 P.2d 840, 844 (1994) (<HOLDING>). III. Conclusion {37} We reverse the district
holding without discussion that since the state tort claims are dismissed there can be no claim for loss of consortium recognizing that loss of consortium is a right of action separate from that of the spouse holding that a loss of consortium is separate and independent from the primary action holding that wifes recovery for loss of consortium should not be reduced by the proportion of negligence attributable to husband because claim for loss of consortium is independent of the damages claim of the injured spouse recognizing loss of consortium claims