Plaintiff-father's alienation of affection claim is summarily dismissed but intentional infliction of emotional distress is timely
In Fujimaki v. Ichikawa, a father sued his son's mother, arguing that after gaining full custody of the boy, she had purposefully engaged in extreme and outrageous conduct that effectively destroyed his relationship with the boy. The trial judge had concluded that the father waited too long to sue and that his claims were barred by the statute of limitations. The Court of Appeals affirmed dismissal of the parental affection claim on that basis, but reinstated the intentional infliction claim, pointing out that from the facts of record, this cause of action had accrued within 3 years of the filing of the complaint and was therefor not stale.