In the past several years, however, North Carolina juries have become even more generous, in 1997 alone handing down $1.2 million against a female paramour in Forsyth County and awarding another jilted wife $1 million in Alamance County and a deceived husband $243,000 in Wake County. In late 1999, a judge in Durham County valued compensatory damages in a case brought by a husband against his wife's lover at less than $3,000 in compensatory damages but the judge still awarded $40,000 in punitive damages on the criminal conversation claim. Since our Supreme Court refused to abolish these causes of action in 1984 and since our legislature has also shown no strong interest in doing so since that time, sizeable damage awards remain a real possibility in North Carolina. At the present time, more than 200 alienation actions are filed in an average year.
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