dissenting.
The common law consistently compensates for interference with the marriage *234relation — “loss of consortium.” Loss of consortium is the second of three elements in an alienation of affection claim. Gibson v. Frowein, 400 S.W.2d 418, 421 (Mo. banc 1966). “The foundation of a cause of action for alienation of affection is the loss of consortium.” Kraus v. Kraus, 693 S.W.2d 869, 873 (Mo.App.1985).
In tort cases where a spouse is injured, the other spouse often has a separate claim for loss of consortium. Powell v. American Motors Corp., 834 S.W.2d 184, 188 (Mo. banc 1992). Most of these losses are caused by a defendant’s negligence. In alienation of affection — an intentional tort — a defendant’s intentional conduct causes the loss. See Gibson, 400 S.W.2d at 421. It is inconsistent that the law compensates for negligent conduct causing a loss of consortium, but (after this opinion) does not compensate for intentional conduct causing the same loss.1
The Restatement (Second) of Torts classifies loss of consortium as an “Indirect Interference with Marriage Relation.” Restatement (Second) of Torts, section 693, p. 495 (1977). The Restatement classifies alienation of affection as a “Direct Interference with Marriage Relation.” Restatement (Second) of Torts, section 683, p. 478 (1977). It is inconsistent that the law compensates for indirect interference with the marriage relation, but (after this opinion) not for direct interference.1
The first reason the majority advances is the “antiquated property concepts” that originally justified alienation of affection. The original justification for loss of consortium was to compensate (only) a husband for his losses from an injury to his wife. Novak v. Kansas City Transit, Inc., 365 S.W.2d 539, 543 (Mo. banc 1963). If the origin of a cause of action is decisive, consistency dictates abolishing loss of consortium claims.
The majority’s second reason is “faulty assumptions.” The majority expresses concern that suits for alienation of affection are brought after a marriage is dissolved or broken. This does not justify abolishing the tort, because claims for loss of consortium may be brought after the marriage relation ends. See Bridges v. Van Enterprises, 992 S.W.2d 322, 325 (Mo.App.1999); Wyatt v. R.D. Werner Co., Inc., 524 N.W.2d 579, 580-81 (N.D.1994); Restatement (Second) of Torts, section 693, cmt. f, p. 497 (1977).
The majority intends to prevent public acknowledgment of the “intimate details” of the marriage and its breakdown. Again, this concern applies equally to loss of consortium claims.
The most common explanation for allowing recovery for loss of consortium by a spouse ... is the impairment or destruction of the sexual life of a married couple by a tort-feasor as an element of damage in the spouse’s consortium action. ... [But] there are other elements, *235such as love, affection, care and companionship ....
Powell, 834 S.W.2d at 188.
The third reason advanced to abolish alienation of affection is “consistency” with abolition of the tort of criminal conversation nine years ago in Thomas v. Siddiqui, 869 S.W.2d 740 (Mo. banc 1994). To the contrary, a rationale for abolishing criminal conversation was that the tort of alienation of affection would still compensate for interference with the marriage relation. Id. at 741.
The Thomas case recognized that — contrary to the majority’s- assertion — there is a difference between the torts. Criminal conversation had only two elements: 1) an actual marriage, and 2) defendant had sexual intercourse with plaintiffs spouse. Id. at 741. The only defense to criminal conversation was consent by the plaintiff. Id. Damages were presumed. Muchisky v. Kornegay, 741 S.W.2d 43, 47 (Mo.App.1987).
Alienation of affection has three elements: 1) defendant’s wrongful conduct; 2) plaintiffs loss of consortium; and, 3) a causal connection between defendant’s conduct and plaintiffs loss. Gibson, 400 S.W.2d at 421. There are various defenses to alienation of affection, including causation, and the lack of wrongful conduct. See Comte v. Blessing, 381 S.W.2d 780, 782, 783-84, 786-87 (Mo.1964); Thornburg v. Federal Express Corp., 62 S.W.3d 421, 426 (Mo.App.2001). Damages must be proved. Kraus, 693 S.W.2d at 874.
In sum, the majority applies consistency at the level of whether the torts protect “the same relational interests.” At this level, today’s opinion calls into question claims for loss of consortium, which also protect marriage relational interests.
I would continue to recognize the tort of alienation of affection, like seven other states — Illinois, Hawaii, Mississippi, New Mexico, North Carolina, South Dakota, and Utah. See Veeder v. Kennedy, 589 N.W.2d 610, 614 n. 6 (S.D.1999). True, six states have previously abolished alienation of affection by judicial decision. See Thomas, 869 S.W.2d at 744 n. 3; Hoye v. Hoye, 824 S.W.2d 422 (Ky.1992). However, three Supreme Courts — having abolished criminal conversation — recently refused to abolish alienation of affection. Bland v. Hill, 735 So.2d 414 (Miss.1999); Veeder v. Kennedy, 589 N.W.2d 610 (S.D.1999); Norton v. Macfarlane, 818 P.2d 8 (Utah 1991).
Because I would leave further action to the General Assembly, I dissent.
. I assume that the majority is also abolishing causes for “infliction of emotional distress” and "tortious interference with contract," where the facts support a claim for alienation of affection. See, e.g., Hellmann v. Walsh, 965 S.W.2d 198, 199-200 (Mo.App.1998); Weicker v. Weicker, 22 N.Y.2d 8, 290 N.Y.S.2d 732, 733-34, 237 N.E.2d 876 (1968); Howton v. Avery, 511 So.2d 173, 174 (Ala.1987); Weaver v. Union Carbide Corp., 180 W.Va. 556, 378 S.E.2d 105, 109 (W.V.1989); Wilson v. Still, 819 P.2d 714, 716 (Okla.1991); Koestler v. Pollard, 162 Wis.2d 797, 471 N.W.2d 7, 11 (1991); Speer v. Dealy, 242 Neb. 542, 495 N.W.2d 911, 913-15 (1993); Cherepski v. Walker, 323 Ark. 43, 913 S.W.2d 761, 767 (1996); Lotring v. Philbrook, 701 A.2d 1034 (R.I.1997); Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235, 1242 (1998); Doe v. Doe, 358 Md. 113, 747 A.2d 617, 623-24 (2000); McDermott v. Reynolds, 260 Va. 98, 530 S.E.2d 902, 903-04 (2000).