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52 Ohio App. 3d 47

556 N.E.2d 1198

Koepke v. Koepke

Ohio Court of Appeals

Decided November 3, 1989

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Ohio Court of Appeals · decided 1989-11-03

Good law ✅— No negative treatment on recordhow we know

Decided 1989-11-03

How this case has been cited

Cited by 20 later decisions — most recently December 2020

16 state decisions

10019891990200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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Glasser, J.

¶1 I respectfully dissent from the majority opinion in this case in holding that a tort action for emotional distress arising from a marital relationship can be pursued separately from a domestic relations action.

¶2 Unfortunately, emotional distress is often present in less than successful marital relationships. Providing an additional forum for the presentation of testimony of this nature may only serve to prolong and increase the level of emotional trauma without deriving any meaningful benefit.

¶3 Justice is best served by limiting this subject matter to the divorce proceedings unless a cause of action for the infliction of physical harm is present.

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