Swartz v. United States Steel Corporation

In 1935 the legislature of Alabama abolished the causes of action for alienation of affection, criminal conversation, seduction of any female person of the age of 21 years or over, and breach of contract to marry. Acts of Alabama, 1935, p. 780. The history of the action for alienation of affections is most interesting. In Woodson v. Bailey, 210 Ala. 568, 98 So. 809 (1924), this court stated that the injury sought to be redressed in a suit for alienation of affections was loss of consortium. At common law an action for alienation of affections was limited to the husband alone. Young v. Young,…