Id., 191 N.W.2d at 709. The McKillip court acknowledged that the federal court in Iowa had ruled otherwise in Wendt v. Lillo, 182 F. Supp. 56 (N.D. Iowa 1960), but the Iowa court declined to follow that authority. McKillip, 191 N.W.2d at 709.
See Kader, The Law of Tortious Pre-Natal Death Since Roe v. Wade, 45 Mo.L.Rev. 639, 663 (1980). E.g., Wendt v. Lillo, 182 F. Supp. 56, 62 (N.D. Iowa 1960) ("Seldom in the law has there been such an overwhelming trend in such a relatively short period of time as there has been in the trend toward allowing recovery for prenatal injuries to a viable infant.") Wendt, a diversity case, involved a claim for prenatal death of a viable fetus under Iowa law, an issue which had not yet been decided by our court. Judge Graven, in concluding Iowa would allow such recovery, relied to a large extent on this trend. See also W. Prosser, Handbook of the Law of Torts ยง 55, at 336 (1971) (beginning in 1946, "a rapid series of cases" allowing recovery for prenatal injuries or death where the child is born alive, "brought about what was up till that time the most spectacular abrupt reversal of a well settled rule in the whole history of the law of torts").