The Pennsylvania Supreme Court has judicially abolished the tort of criminal conversation, extinguishing the last civil remedy available against an outsider who engages in sexual relations with another's spouse.
Fadgen v. Lenkner, 469 Pa. 272, 365 A.2d 147 (1976).
Torts - Interference with the Marital Relationship - Criminal Conversation,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol15/iss4/8