Suits Historically at common law, spouses were not allowed to sue one another at all. Initially, this was due to the doctrine of coverture. Even after this legal doctrine was abandoned with the adoption of the Married Women's Property Acts, many courts disallowed lawsuits between spouses other than divorce or criminal proceedings for the fear that it would disrupt marital harmony. From the 1860s until 1913, courts completely rejected the notion of interspousal liability. Then, in 1914, one woman was allowed to bring a civil suit against her husband for assault and false imprisonment. Between 1914 and 1920, there were seven state supreme courts that allowed spouses to sue one another for claims such as assault and battery, wrongful imprisonment, wrongful death, and infliction of venereal disease. However, recognition of spouses' ability to sue one another stalled around 1921. Scholars suggest this change in direction is due to the rise of tort suits arising out of automobile accidents. Courts declined to extend spouses the ability to sue each another after car accidents for fear of collusion and insurance fraud. This fear stems from the fact that both sides of a negligent car accident suit between spouses want the injured party to recover. Courts then blurred the lines between willful and negligent tort suits to disallow any interspousal tort suits. This argument contrasts the popular narrative that patriarchal restrictions were responsible for interspousal immunity from suit. Public authorities Dolan v. United States Postal Service, post office immune under the Federal Tort Claims Act Feres v. United States, 340 U.S. 135 (1950), US immune from suit from members of the military Warren v. District of Columbia, 444 A.2d. 1, D.C. Ct. of Ap. (1981) holding that the police were not responsible for failing (though repeatedly warned) to respond to calls and arrest people committing crimes Damages Joint liability Walt Disney World Co. v. Wood, 489 So. 2d 61 (Fla. Dist. Ct. App. 1986) Comparative negligence Li v. Yellow Cab Co., 532 P.2d 1226, 13 Cal.3d 804 (1975), Punitive damages Punitive damages (sums intended to punish the defendant) may be awarded in addition to actual damages intended to compensate the plaintiff. Punitive damage awards generally require a higher showing than mere negligence, but lower than intention. For instance, grossly negligent, reckless, or outrageous conduct may be grounds for an award of punitive damages. These punitive damages awards can be quite substantial in some