There are exceptions to this : in North Carolina, a spouse can sue a third party for causing " loss of affection " in or " criminal conversation " ( adultery ) with their spouse, and more than twenty states in the US have laws against adultery although they are infrequently enforced.
32.
In the case of " Cannon v . Miller ", 71 N . C . App . 460, 322 S . E . 2d 780 ( 1984 ), the North Carolina Court of Appeals ( the state's intermediate appellate court ), abolished the tort of criminal conversation, as well as the tort of alienation of affections, in the state.
