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Arguably, the heart balm torts have outlived their relevance in a society where marriage is no longer a necessary imprimatur for intimate relations, and where broken hearts and failed marriages are the statistical norm. A state’s resolute rejection of the heart balm torts in principle as well as applied to modern domestic relations mores need be checked neither by Constitutional protections of marriage nor by the need for uniformity among sister states. Therefore, one state need not and must not transport its domestic relations public policy across state lines. Mississippi’s expansive jurisdictional embrace of nonresidents, John Daly and Anna Cladakis, based upon their alleged temporary embrace of each other, violates Anna Cladakis’ due process rights while providing a forum for Daly’s opportunistic ex-wife to pursue publicity and monetary damages by vitiating the clear public policy of her home state of Tennessee.



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