Koestler v. Pollard

Although the facts of this case might also have formerly given rise to an alienation of affection and *810criminal conversation action, I would hold that the plaintiffs claim for intentional infliction of emotional distress is not expressly barred by sec. 768.01, which eliminated alienation of affection and criminal conversation actions, and is not barred by public policy. Accordingly, I would reverse the order of the circuit court and hold that the complaint states a claim for which relief may be granted.

HH

While sec. 768.01, Stats. 1987-88, specifically abolishes all causes of action for…