Does extreme cruelty constitute a separate cause of action for divorce?

California, United States of America

The following excerpt is from Verdier v. Verdier, 203 Cal.App.2d 724, 22 Cal.Rptr. 93 (Cal. App. 1962):

Other California cases have recognized the principle of the separability of causes of action for divorce. Thus in Haskell v. Haskell (1880) 54 Cal. 262, 263, the court states 'That adultery or habitual intemperance would in a popular sense constitute extreme cruelty, we do not question. And so would willful desertion or willful neglect. But, in a legal sense, extreme cruelty is something different from any of the other causes of divorce, and constitutes a separate and distinct cause of action.'

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Does extreme cruelty constitute a separate cause of action for divorce?

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