Note 23 — Chapter I · INTENTIONAL INTERFERENCE
Reading edition
Beseler v. Stephani, 71 Ill. 400; Woodward v. Anderson, 9 Bush, 624; Paul v. Frazier, 3 Mass. 71; Welsund v. Schueller, 98 Minn. 475; Robinson v. Musser, 78 Mo. 153; Hamilton v. Lomax, 26 Barb. 615; Weaver v. Bachert, 2 Pa. St. 80; Conn v. Wilson, 2 Overt. 233 Accord. See Desborough v. Homes, 1 F. & F. 6.
An action is allowed by statute in some jurisdictions. Marshall v. Taylor, 98 Cal. 55; Swett v. Gray, 141 Cal. 83; McIlvain v. Emery, 88 Ind. 298; Verwers v. Carpenter, 166 Ia. 273; Watson v. Watson, 49 Mich. 540; Hood v. Sudderth, 111 N. C. 215; Breon v. Henkle, 14 Or. 494. The Scotch law is to the same effect. Smith, Law of Damages in Scotland, 128. Under these statutes it has been held that there must be a real seduction: “Consent must be procured by some trick or artifice other than mere solicitation.” Brown v. Kingsley, 38 Ia. 220. Compare Breon v. Henkle, 14 Or. 494.
Even without a statute a guardian is liable in damages for the seduction of his ward. Graham v. Wallace, 50 App. Div. 101. See also Smith v. Richards, 29 Conn. 232.