Hanson v. Valdivia

Two issues are presented on this appeal:(1) Does a cause of action for criminal conversation or alienation of affections survive the death of the wronged party when the complaint alleges no damage to the property rights or interests of the deceased?(2) May the special administrator of the decedent’s estate maintain an action for wrongful death when there is a surviving spouse who has participated in the wrongful conduct which allegedly caused the wrongful death?

Howard v. Lunaburg (1927), 192 Wis. 507, 213 N. W. 301, sets forth the rule that actions for criminal conversation or alienation of…