Note 607 — Chapter XVIII · PROBLEMS OF MARRIAGE AND THE FAMILY

The doctrine of his own decision was formulated in 1826 by Kent in the first edition of his Commentaries. Ten years earlier, in 1816, it had been accepted by Reeve, former chief justice of Connecticut, in his treatise on the Law of Husband and Wife. It was followed in 1842 by Greenleaf in his work on Evidence; and later by Bishop in his well-known book on Marriage and Divorce. On the other hand, the younger Parsons, the first edition of whose Contracts appeared in 1853, is inclined to reject the Kent doctrine: see the 8th ed., II, 78 ff.; and compare Cook, "The Mar. Cel. in the U. S.," Atlantic, XLI, 521, 522.