[742] 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.
[743] Wright, Report, 162-64. In the whole country, during the years 1867-86, 328,716 decrees were granted, representing probably 484,683 petitions.
[744] In forty-five counties in twelve states, for the period 1867-86, notice was served by publication in 9,944 cases; in 17,040 cases personal service was made; and in 2,681 cases no evidence on the point was obtainable: Wright, Report, 201, 202.
[745] For a good discussion of the scope of various statutory grounds of divorce, with the defenses, as actually interpreted by the courts, see Whitney, Marriage and Divorce, 108-56; and compare Bishop, Mar., Div., and Sep., I, 610 ff., II, 1 ff.; Stewart, Law of Mar. and Div., 203 ff.; Lloyd, Law of Div., 147 ff., 180 ff.; Convers, Mar. and Divorce, 180 ff.
[746] The ninety-nine illustrations of the allegations of the plaintiff presented in Wright's Report, 172-78, constitute very interesting reading. Some of them are quoted by Bryce, Studies in Hist. and Jurisp., 835, 836. The frauds arising in the procedure are forcibly described by Judge Jameson, "Divorce," North Am. Rev., CXXXVI, 323, 324; and the conflicts in laws by Phillips, "Divorce Question," Internat. Rev., XI, 139-52.
[747] Wright, Report, 139-42.
[748] According to the table by classified causes: Wright, Report, 181-83. However, the relative number of divorces granted on the wife's petition varies greatly among the states: from 39.3 per cent. in North Carolina to 77.9 in Nevada: compare the table in Willcox, The Divorce Problem, 34-37.
[749] Dike, "Statistics of Marriage and Divorce," Pol. Sci. Quart., IV, 607, summarizing the tables and figures in Wright, Report, 135-39.
[750] Wright, Report, 137.
[751] Ibid., 147-49.