In Goode v. Martinis, the Washington Supreme Court held that a wife has a cause of action in tort for an assault committed upon her by her husband while the parties are legally separated and divorce proceedings are pending. While restricting its holdings to the particular facts, the court rejected the rationale advanced in favor of the common law doctrine of spousal disability.
Richard H. Williams,
Washington Case Law,
Torts—Interspousal Actions—Personal Torts,
37 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol37/iss2/19