• Key point. Many states have repealed laws that once permitted a person whose spouse was seduced by another individual to sue for "alienation of affections." Husbands whose wives are seduced by clergy may be barred from suing for damages in such states.

The Arkansas Supreme Court ruled that a man could not sue a priest and bishop as a result of the priest's seduction of his wife. A couple were married in 1972. Five children were born to the marriage. In 1986, the wife (Susan) became employed with the local Roman Catholic Diocese. In 1988, a new priest arrived at the Diocese. The priest was placed in charge of the Diocese Marriage Tribunal, having authority over Catholic marriages in the Diocese. Shortly after his assumed his new duties, he began spending his days off with Susan, taking all day trips out of town with her, and staying at her residence several nights a week until late in the evening, drinking alcohol to the point of intoxication. On one occasion, while Susan's husband was stranded out of town in an ice storm, the priest spent the night with Susan at her home. On another occasion, the priest stayed the night with Susan and her family at their lake house. The priest and Susan stayed up until the "wee hours drinking and cavorting in the bedroom," and Susan did not come to bed that evening with her husband. While her husband felt that the priest's conduct "seemed highly improper," he had no proof that he was having an affair with Susan. Over the next several months the husband became increasingly concerned over the accelerating "friendship" between Susan and the priest. In 1989, Susan sued her husband for divorce and moved into a home owned and furnished by the Diocese. The husband thereafter tried unsuccessfully to enlist the assistance of the bishop in removing the priest from his family life (although the bishop had no recollection of ever discussing the matter with him).