The North Carolina Court of Appeals has held:
Quote Quoting Cooper v. Shealy, 140 N.C. App. 729, 537 S.E.2d 854 (2000)
However, we note that the issue of determining which state's substantive law is applicable to plaintiff's laims for alienation of affections and criminal conversation is not before us. For instance, since alienation of affections is a transitory tort, the substantive law of the state where the tort occurred is the applicable law. See Darnell v. Rupplin, 91 N.C. App. 349, 371 S.E.2d 743 (1988). Therefore, plaintiff must prove that the tortious injuries, defendant's alienation of her husband's affection and criminal conversation, occurred in North Carolina before North Carolina substantive law can be applied. Id. Nevertheless, we find that North Carolina has jurisdiction to hear this case.
However, the Cooper court did not decide choice of law questions, leaving open the question of whether the defendant's conduct would be judged under NC law or the law of the state in which he acted. If Michigan law applies there would be no recovery, as Michigan does not permit actions for alienation of affection.