Note 65 — Chapter XVII · A CENTURY AND A QUARTER OF DIVORCE LEGISLATION IN THE UNITED STATES, 1776-1903
Reading edition
In 1835 a divorce is authorized "where the consent of one of the parties to the marriage was obtained, by gross and deliberate fraud or false pretences ... provided the parties have not cohabited, as husband and wife, after such fraud was known to the party, thus deceived."—Pub. Acts (1835), 177. Habitual drunkenness was added in 1838: Pub. Acts (1838), 499, 500; cf. Rev. Stat. (2d ed., 1847), 364.