Fundermann v. Mickelson

HARRIS, Justice.

We have become convinced that there is inherent and fatal contradiction in the term “alienation of affections.” The alienation belies the affection. Suits for alienation are useless as a means of preserving a family. They demean the parties and the courts. We abolish such a right of recovery and, hence, reverse and set aside the trial court’s judgment.

It is scarcely necessary to relate the facts. As is typical, there was ample defense evidence that the marriage between the plaintiff and his former wife, Susan, had deteriorated to a point of no return long prior to defendant’s involvement. Predictably, there was also the plaintiff’s evidence that the marriage was not unusually or hopelessly stormy until Susan’s amorous affair with defendant. There have been two marriage dissolutions and Susan is now married to defendant.

I. The trial court, as mandated, by our prior decisions, Bearbower v. Merry, 266 N.W.2d 128 (Iowa 1978), submitted these conflicting versions of the evidence for the jury’s resolution. In our past reviews of alienation awards we have dutifully acknowledged and yielded to the jury’s prerogative in establishing facts from conflicting evidence. Iowa R.App.P. 14(f)(1).

Our. system of establishing facts,. however, has a strong, sometimes it seems an irresistible, tendency to break down in alienation cases. This is because of the incendiary effect of the usual evidence in such cases. Under the established theory of recovery, the jury should first undertake to decide which came first, the marriage breakdown or the misconduct. But juries necessarily face that first determination after learning of conduct of which they strongly disapprove and which society condemns.

It is illogical to pretend that juries can dispassionately resolve the factual disputes in alienation suits in the same manner as in other cases. There is a strong indication the jury was unable to do so here because it apparently rejected the testimony of plaintiff’s and Susan’s own daughter, Kathleen Neumiller. She testified she left home in 1974, before her final year of high school. This was before plaintiff says Susan became involved with defendant. Kathleen said, “I didn’t feel there was any love in the family. I didn’t feel there was any love toward me or toward each other, my mother and father.”

But we certainly should not condemn juries for the impossible difficulty they face in sorting out the contested facts in alienation suits. It is the theory of recovery that is flawed. That theory was rooted in ideas we have long since renounced, involving wives as property. The action has survived in the hope that it affords some protection to existing family relationships. But this lofty hope has proven illusory. Human experience is that the affections of persons who are devoted and faithful are not susceptible to larceny — no matter how cunning or stealthful. And it is folly to hope any longer that a married person who has become inclined to philander can be preserved within an affectionate marriage by the threat of an alienation suit. If we did *792pretend that a would-be paramour would be thereby dissuaded, a substitute is likely to be readily found.

Increasingly, the states reject and renounce the right of an alienation recovery because the existence of such a right is itself a slander on marriage. As pointed out in Bearbower, 266 N.W.2d at 137 (dissenting opinion):

Still another [reason for abolishing the suit] is the peculiar light which the whole proceeding throws on the nature of marriage, leaving one with the conviction that the successful plaintiff has engaged in something which looks very much like a sale of his wife’s affections. Most significantly of all, the action for alienation is based on psychological assumptions that are contrary to fact.

Quoting H. Clark, Law of Domestic Relations, § 10.2 at 267 (1968).

II. There is an unmistakable trend away from allowing alienation suits. While Bear-bower was under submission Minnesota, by statute, abolished the right. Since then Georgia has. Not mentioned in Bearbower is the fact that Rhode Island had joined the states which limit recoveries by short statutes of limitation. Washington has abolished the right by judicial pronouncement. So now, in eighteen states and the District of Columbia, alienation actions have been totally abolished by statutes. Ariz.Rev. Stat.Ann. § 25-341 (West Supp. 1980-81); Cal.Civ.Code § 43.5 (West 1954); Colo.Rev. Stat. § 13-20-202 (1973); Conn.Gen.Stat. Ann. § 52-572b (1977); D.C.Code Encycl. § 16-923 (West Supp. 1978-79); Del.Code Ann. tit. 10, § 3924 (1975); Ga. Code Ann. § 105-1203 (Harrison Supp. 1980); Ind.Stat. Ann. § 34-4-4-1 (Burns Supp. 1980); Me. Rev.Stat.Ann. tit. 19, § 167 (West Supp. 1980-81); Md.Ann.Code, Courts and Judicial Proceedings § 5-301(a) (1980); Mich. Stat.Ann. § 600.2901 (1968); Minn.Stat. Ann. § 553.01 (West Supp. 1980); Mont. Code Ann. § 27-1-601 (1979); Nev.Rev. Stat. § 41.380 (1979); Or.Rev.Stat. § 30.840 (1975); Va.Code § 8.01-220 (1977); W.Va. Code § 56-3-2a (Michie Supp. 1980); Wis. Stat.Ann. § 238.01 (West Supp. 1980-81); Wyo.Stat. § 1-23-101 (1977).

In Louisiana, the cause of action has never existed. Moulin v. Monteleone, 165 La. 169, 178, 115 So. 447, 451 (1927), accord, Ohlausen v. Brown, 372 So.2d 787, 788 (La.Ct.App.1979).

Recently, Washington became the first state to judicially abolish the action for alienation of a spouse’s affection. Wyman v. Wallace, 94 Wash.2d 99, 104, 615 P.2d 452, 455 (1980).

Six states deny the recovery of money damages in alienation actions. Ala.Code tit. 6, § 5-331 (1978) (abolishes recovery for female 19 years or older) (injunction still permitted), see Logan v. Davidson, 282 Ala. 327, 330, 211 So.2d 461, 463 (1968); Fla.Stat. Ann. § 771.01 (West 1964); N.J.Stat.Ann. § 2A:23-1 (West 1952); N.Y.Civ. Rights Law § 80-a (Lawyers Coop. 1974); Ohio Rev. Code Ann. § 2305.29 (Supp.1979); Vt. Stat.Ann. tit. 15, § 1001 (1976).

Three states, while retaining the suit, view it with some disfavor. Ferriter v. Daniel O’Connell’s Sons, Inc., - Mass. -, Mass.Adv.Sh. Sept. 19, 1980 at 2081-82, 413 N.E.2d 690 (alienation actions are disfavored); Dube v. Rochette, 110 N.H. 129, 130, 262 A.2d 288, 289 (1970) (action susceptible to abuse, but legislature’s judgment to allow continuance of action must be respected); Thompson v. Chapman, 93 N.M. 356, 358, 600 P.2d 302, 304, cert. denied, 92 N.M. 675, 593 P.2d 1078 (N.M.Ct. App.1979) (would be abolished if court had authority to do so).

Two states have abolished the action with some exceptions. Okla.Stat.Ann. tit. 76, § 8.1 (West Supp. 1980-81) (action permitted only if spouse was incompetent or a minor); Pa.Stat.Ann. tit. 48, § 170 (Purdon 1965) (action can only be brought against a relative of wayward spouse).

Three states have shortened their statute of limitations on alienation actions to just one year. Ark.Stat.Ann. § 37-201 (Bobbs-Merrill Supp. 1979); Ky.Rev.Stat.Ann. § 413.140(l)(c) (Bobbs-Merrill Supp. 1978) (includes alienation actions); Skaggs v. Stanton, 532 S.W.2d 442, 443 (Ky.1975); R.I.Gen. Law § 9-1-14 (Bobbs-Merrill Supp. 1980).

*793One state limits recovery to just actual damages. Ill.Code Ann. ch. 68, § 35 (Smith-Hurd 1959).

Eleven states employ burden of proof requirements similar to that used by the Iowa court. Compare Summerfield v. Pringle, 65 Idaho 300, 308, 144 P.2d 214, 218 (1943) (defendant’s action must be the controlling cause of the alienation); Poulos v. Poulos, 351 Mass. 603, 607, 222 N.E.2d 887, 891 (1967) (defendant’s action must be the controlling cause of the alienation); Hansen v. Strohschein, 178 Neb. 367, 369, 133 N.W.2d 598, 599 (1965) (controlling cause); Dube v. Rochette, 110 N.H. 129, 130, 262 A.2d 288, 289 (1970) (controlling cause); Lueg v. Tewell, 572 S.W. 97, 102 (Tex.Civ.App.1978) (must be controlling cause) with Bearbower v. Merry, supra, at 130 (defendant’s action must be the controlling cause of the loss of affection). See Stanton v. Cox, 162 Miss. 438, 450, 139 So. 458, 461 (1932) (direct interference by defendant must have caused the wayward spouse’s infatuation with defendant); Sutton v. Sutton, 567 S.W.2d 147, 148 (Mo.Ct.App.1978) (plaintiff need only show causal connection between defendant’s conduct and alleged loss); Tice v. Mandel, 76 N.W.2d 124, 129 (N.D.1956) (requires only causal connection); Holloway v. Holloway, 204 S.C. 565, 569, 30 S.E.2d 596, 597 (1944) (requires only causal connection); Wilson v. Bryant, 167 Tenn. 107, 113, 67 S.W.2d 133, 135 (1933) (plaintiff must show that defendant was the pursuer and not the pursued); Sadleir v. Knapton, 5 Utah 2d 26, 29, 296 P.2d 278, 280 (1956) (defendant’s action must be resulting cause).

Four states employ more difficult burdens of proof. Hunt v. Chang, 594 P.2d 118, 123 (Haw.1979) (five-prong burden of proof); Long v. Fischer, 210 Kan. 21, 25-26, 499 P.2d 1063, 1067 (1972) (five-prong test for burden of proof); Thompson v. Chapman, 93 N.M. 356, 358, 600 P.2d 302, 303-04, cert. denied, 92 N.M. 675, 593 P.2d 1078 (N.M.Ct.App.1979) (plaintiff must show existence of affection and that defendant maliciously caused the alienation by direct interference); Heist v. Heist, 46 N.C.App. 521, 523, 265 S.E.2d 434, 436 (1980) (plaintiff must show existence of genuine love and that malicious acts of defendant produced the loss).

One state, Alaska, has no reported case law on the issue.

It is sometimes suggested that the abrogation of a right, even a common-law right, should come from the legislature rather than from the courts. This suggestion was already laid to rest in Bearbower. In Bearbower, though we were in wide disagreement on the underlying and fundamental issue in the case, we were unanimous in believing it was for us and not for the legislature to end the right of this recovery if it were to be ended.

Two other justifications are urged in favor of retaining alienation suits. It is suggested that the doctrine of stare decisis would be impugned by abolition of the doctrine in view of the recentness of our decision in Bearbower. But, as our majority opinion in Bearbower noted: “Of course it is our duty to monitor and interpret the common law, and to abandon antiquated doctrines and concepts. [Authorities.] The genius of the common law is its flexibility and capacity for growth and adaptation. [Authority.]” 266 N.W.2d at 129.

The doctrine of stare decisis was no deterrent to the Washington Supreme Court which, in the case of Wyman v. Wallace, supra, reconsidered its earlier opinion of 91 Wash.2d 317, 588 P.2d 133. On reconsideration the Washington court abolished the right to maintain alienation suits, a right it had expressly retained in its original opinion in the same case.

On other questions our court has not hesitated to re-examine and revise rules and doctrines, even those we have recently ratified. See for example Bierkamp v. Rogers, 293 N.W.2d 577 (Iowa 1980). And in Kersten Co., Inc. v. Department of Social Services, 207 N.W.2d 117 (Iowa 1973), notwithstanding a recent refusal to do so, we overturned a rule which had recognized governmental immunity in contract suits. We were strongly urged to continue the old rule for the sake of consistency. Rejecting the argument we said:

*794We have not been reluctant in the past to overrule prior decisions when we conclude they are wrong. Stare decisis is a valuable legal doctrine which lends stability to the law, but it should not be invoked to maintain a clearly erroneous result simply because that’s the way it has been in the past. Certainly we should be as willing to correct our own mistakes as we are those of others. [Authorities.]

207 N.W.2d at 121.

There is also some suggestion that abolition of the suit is out of step with our pronouncements affirming a right to recover for loss of consortium. But, as pointed out in the Bearbower dissenting opinion, 266 N.W.2d at 137, there is nothing inconsistent in the allowance of the one and the abolition of the other. The right to recover for loss of consortium is a factor in assessing damages when underlying liability has been established in a personal injury suit. Renunciation of the right to recover for alienation proceeds from the belief there is no basis for the underlying liability.

In the last analysis we think the action should be abolished because spousal love is not property which is subject to theft. We do not abolish the action because defendants in such suits, need or deserve our protection. We certainly do not do so because of any changing views on promiscuous sexual conduct. It is merely and simply because the plaintiffs in such suits do not deserve to recover for the loss of or injury to “property” which they do not, and cannot, own.

REVERSED.

All Justices concur except ALLBEE, J., who concurs specially and REYNOLDSON, C. J., and LeGRAND, McGIVERIN, and SCHULTZ, JJ., who dissent.