Bruce V. Nguyen


The tort of alienation of affection was first recognized in New York in 1866 and was eventually adopted by almost every jurisdiction in the United States. Missouri had recognized the tort as early as 1881 and continues to recognize it to this day. Most jurisdictions, however, have subsequently abolished the action either judicially or by statute. This Note will first present the facts and holding of the instant case, Thornburg v. Federal Express Corp. It will then provide the legal background by briefly discussing the history of the tort of alienation of affection, the related tort of criminal conversation in Missouri, the tort as applied to the employer-employee setting and the recent trend to abolish the common law action. Finally, the Note will argue that Missouri should follow the general trend and abolish the tort as well.

Included in

Law Commons



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.