McDermott v. Reynolds

In this appeal, we consider whether Code § 8.01-220 bars a plaintiff’s action against his former wife’s paramour for intentional infliction of emotional distress, when the conduct alleged would support an action for alienation of affection, a cause of action specifically prohibited by the statute.

Glenn R. McDermott filed a motion for judgment against William Reynolds for intentional infliction of emotional distress based on Reynolds’ alleged conduct in maintaining an adulterous relationship with McDermott’s wife. Reynolds demurred to the motion for judg ment, asserting that McDermott’s action…