Ohio Revised Code

Ohio Rev. Code § 2305.29 (2026)

No civil liability for breach of a promise to marry, alienation of affections, or criminal conversation

✓ current as of May 2026
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No person shall be liable in civil damages for any breach of a promise to marry, alienation of affections, or criminal conversation, and no person shall be liable in civil damages for seduction of any person eighteen years of age or older who is not incompetent, as defined in section 2111.01 of the Revised Code.

Notes of Decisions
Cited in 42 cases (2 in the last 5 years), 1981–2024 · leading case: Strock v. Pressnell, 527 N.E.2d 1235 (Ohio 1988).
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Strock v. Pressnell, 527 N.E.2d 1235 (Ohio 1988). · cites it 24× “5 B We next address whether appellant can assert a claim against Pressnell for intentional infliction of emotional distress in light of R.C. 2305.29, the statute that abolished amatory actions.”
Mussivand v. David, 544 N.E.2d 265 (Ohio 1989). · cites it 5× “Appellant also contends that ap-pellee’s complaint is barred by R.C. 2305.29, the so-called “anti-heart balm” statute.”
Slusher v. Oeder, 476 N.E.2d 714 (Ohio Ct. App. 1984). · cites it 19× “R.C. 2305.29 provides that: “No person shall be liable in civil damages for any breach of a promise to marry, alienation of affections, or criminal conversation, and no person shall be liable in civil damages for seduction of any person eighteen years of age or older who is not…”
Wilson v. Dabo, 461 N.E.2d 8 (Ohio Ct. App. 1983). · cites it 10× “Plaintiff, Cheryl Wilson, appeals from a judgment of the Franklin County Court of Common Pleas dismissing her complaint for failure to state a claim upon which relief could be granted on the ground that the complaint was for breach of promise to marry and, therefore, barred by…”
Haskins v. Bias, 441 N.E.2d 842 (Ohio Ct. App. 1981). · cites it 15× “Finding that R.C. 2305.29 had abolished civil liability for the commission of the torts alleged in the counterclaim, the court entered judgment on January 16, 1981, granting the motion to dismiss.”
Simpkins v. Grace Brethren Church of Delaware, Ohio (Slip Opinion), 2016 Ohio 8118 (Ohio 2016). · cites it 2× “2d 1235 (1988) (holding that R.C. 2305.29’s elimination of common-law amatory actions was constitutional because there was “ ‘no property or vested right in any of the rules of the common law, as guides of conduct’ ”), quoting Leis v.”
Dixon v. Smith, 695 N.E.2d 284 (Ohio Ct. App. 1997). · cites it 4× “First, Harold argues that since Karen’s claims are based upon a broken promise of marriage, they are barred by R.C. 2305.29, Ohio’s “heart balm” statute.”
Ruther v. Kaiser, 2012 Ohio 5686 (Ohio 2012). · cites it 2× “R.C. 2305.29; Strock v. Pressnell, 38 Ohio St.”
Williams v. Ormsby, 2012 Ohio 690 (Ohio 2012). · cites it 2× “For instance, amatory causes of action were abolished in 1978 through R.C. 2305.29, see also Strock v. Pressnell, 38 Ohio St.”
Vrabel v. Vrabel, 459 N.E.2d 1298 (Ohio Ct. App. 1983). · cites it 7× “1 *266 II A The question raised by the first assignment of error is, broadly, whether the Ohio “heart balm” statute, R.C. 2305.29, denies due process and/or equal protection under the United States Constitution and due course of law and equal protection 2 under the Ohio…”
Nelson v. Jacobsen, 669 P.2d 1207 (Utah 1983). · cites it 2× “Rights Law § 80-a (McKinney 1976); Ohio Rev. Code Ann. § 2305.29 (Page 1981); Vt.”
Hunt v. Hunt, 309 N.W.2d 818 (S.D. 1981). · cites it 2× “In accord with these authorities, we believe that alienation of affections and criminal conversation, as viable legal remedies, are outmoded archaic holdovers from an era when wives [3] were considered the chattel of their spouse rather than distinct legal entities.”
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