## Facts

- Clara Marie Pyle was the natural mother of Donald Waechter, a minor.
- For roughly a decade, Donald lived in the household of the defendants, who were associated with the child’s father’s family.
- Pyle sued the defendants for damages, alleging they maliciously caused Donald to lose respect, love, and affection for her.
- The alleged misconduct consisted of influencing the child’s feelings and attitudes (“poisoning” his mind), not abducting, concealing, detaining, or physically restraining him.
- Pyle did not base her claim on loss of the child’s services or on deprivation of legal custody; she sought recovery primarily for mental suffering from the child’s estrangement.

## Issues

1. Whether Iowa law recognizes a tort action for damages by a parent against third parties who, without abducting or detaining a minor child, maliciously alienate the child’s affections from the parent.
2. Whether a parent’s legally protected interests in a minor child extend beyond custody and services to include the child’s affection as an independent basis for tort liability.

## Decision

- The Iowa Supreme Court affirmed judgment for the defendants.
- The court held that Iowa law does not provide an independent cause of action for malicious alienation of a minor child’s affections where there is no interference with custody, control, or services.
- The plaintiff mother recovered no damages.

## Legal Principles

- A parent’s legally protected interests in relation to a minor child are centered on custody, care, control, and (historically) services, rather than the child’s affection as a standalone, compensable interest.
- Traditional tort actions involving children (e.g., enticement, abduction, harboring) depend on tangible interference with the parent’s legal rights, not merely the child’s emotional estrangement.
- Claims premised solely on loss of affection and mental anguish from third-party influence are disfavored as speculative, difficult to prove, and likely to invite unreliable litigation over domestic disputes.

## Conclusion

The court refused to extend tort liability to alleged malicious influence that caused a minor child to withdraw affection from a parent, reaffirming that, absent interference with custody or services, Iowa law did not treat alienation of a child’s affections as an actionable wrong in damages.


Pyle v. Waechter, 202 Iowa 695, 210 N.W. 926 (Iowa 1926)