On Thursday in Knight v. Woodfield the Mississippi Supreme Court ruled that Mississippi’s long-arm statute covered a Louisiana resident who had an affair with a Mississippi resident. The ruling allows the perpetrator’s former spouse to maintain an alienation of affection lawsuit against the Louisiana resident. Here is the Court’s opinion.


A Harrison County resident cheated on her husband with a co-worker at her job in Mississippi. The sex took place in Louisiana. Her now ex-husband sued for alienation of affections in Harrison County County Court.


By a 7–2 vote the Court ruled that the Mississippi long-arm statute covered the non-resident defendant. Justice Carlson wrote the majority opinion. The other Justices in the majority were Graves, Dickinson, Randolph, Lamar, Kitchens and Pierce.

The majority ruled that a bunch of emails and text messages satisfied the minimum contacts requirement of the long-arm statute.

Chief Justice Waller dissented and Justice Chandler joined the dissent. The dissent argued that the defendant did not have sufficient minimum contacts with Mississippi.

My Take:

I’m in the dissent camp on this one, but my opinion is jaded by my disdain for the alienation of affection cause of action.

The cause of action has multiple problems, is unproductive and should be abolished.

The defendant was also a non-Mississippi resident in this October verdict in an alienation of affection trial in federal court.