All men could be seducers only certain types of women could be seduced. by his flattery or deception.” Likewise consent, or failure to resist, or evidence that “she had previously prostituted herself to the embraces of other men” could be a defense for the man. The victim had to have been moved “by some promise or artifice. Dill the court held that evidence of active and organized misrepresentation was key to determining whether seduction had occurred. Courts combined legal and moral principles to articulate what seduction was, who a seducer was, and who the law would identify as a victim of seduction. These reforms led to the development of a new language to describe sexual behavior. By 1913, 18 states had enacted reforms liberalizing the use of the seduction tort. The movement began in Michigan in 1846 and soon spread around the country. Initially this involved the reform of the civil suit of Seduction such that women could bring suits against men on their own initiative.
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