 It has since been abolished in several states, including those adopting or influenced by the Model Penal Code, section 2.09(3) of which expressly ends the presumption and abolishes the defense.In Ireland the case of "State (DPP) v Walsh and Conneely" in 1981 found that presumption of marital coercion had not survived the enactment of the 1937 Constitution and so the defence is no longer available there.By the Crimes (Amendment) Act 1924, paragraph 4 of Schedule 3 to the Crimes Act 1900 abolished the defence in New South Wales, Australia.