Slusher v. Oeder

I concur with the majority’s disposition of the first and second assignments of error, but I must dissent from their disposition of the third assignment because I am not convinced that the Supreme Court has “implicitly resurrected” civil actions for alienation of affection by recognizing actions for negligent or intentional infliction of emotional distress.

Before the advent of R.C. 2305.29, which abolished civil actions for alienation of affection, a cause of action for alienation of affections existed if the aggrieved spouse could prove that defendant “wrongfully, maliciously and…