Adequate protection in the nature of injunctive relief has been extended to all branches of the law where there is a primary property right to be protected. Despite the rapid development in the field of equitable relief it has always been considered extraneous to actions in domestic relations. The majority of the courts will not protect marital and domestic rights from third party intervention because such action involves a personal right rather than a necessary property right. There is adequate reason for a change in this precept which delegates personality to such an insecure position. Only a limited number of the courts in the United States have recognized the need for the extension of protection to purely personal rights.
Moss H. Thompson, The Equitable Theory of Injunction in Domestic Relations, 1 Clev.-Marshall L. Rev. 45 (1952)