Note 742 — Chapter XVIII · PROBLEMS OF MARRIAGE AND THE FAMILY

See Streitwolf v. Streitwolf (1900), Opinions of U. S. Supreme Court, No. 13, p. 553, involving a decree of divorce granted in North Dakota to a resident of New Jersey; Bell v. Bell (1900), ibid., 551, voiding a similar judgment secured in Pennsylvania by a resident of New York; and S. v. Armington (1878), 25 Minn., 29-39, in which a divorce granted in Utah to a resident of Minnesota in 1876 was declared void for want of jurisdiction. Similar decisions, involving the notorious fraudulent divorces obtained in Utah before the change of the law in 1878, "have been reached in criminal trials in New York, Indiana, and Iowa, and in civil suits in Massachusetts, Kansas, and Tennessee"—the earliest in 1877: Willcox, "A Study in Vital Statistics," Pol. Sci. Quart., VIII, 86 n. 1.