The doctrine of parental immunity, in its original form, prevented children from suing their parents in tort.' Although the immunity once enjoyed almost universal acceptance, it has been the target of modem criticism. In Missouri, parental immunity only prevented minors from asserting causes of action based in negligence against their parents.' Over time, Missouri courts limited the application of parental immunity to actions by unemancipated minors which could jeopardize family relations. In Hartman v. Hartman, the Missouri Supreme Court wholly abolished parental immunity and adopted a "reasonable parent" standard of care.

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