thoughts: The Fifth Circuit joined the Ninth Circuit in imposing a necessity that "looking after" An ill comparative requires provision of some actual care in close and continuing proximity to the ill member of the family. regarding the "genuine care" necessitie, The decision is not surprising in that Baham telephone contacts were with his wife, Not his daughter or his daughter physicians. The situation would doubtless have been different had he been consulting with his wife and doctors about alternatives for his daughter.

we can not