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THERE is no topic in the conflict of la\vs so full of legal difficulties today as the migratory divorce problem. Williams v. North Carolina I and II have not found a solution to this problem, but still insist for the recognition of interstate divorce upon the acquisition of a bona fide domicil.

Public opinion in America has always been greatly divided on the social desirability of "easy" divorces. Early in the 19th century there was a great deal of complaint in Massachusetts concerning the "easy" Vermont divorces. Massachusetts did not allow divorce at that time for extreme cruelty, whereas Vermont did. Furthermore Vermont permitted divorce without any settled domicil. Judge Sewell of the Supreme Judicial Court of Massachusetts, referring to the lax Vermont laws of his time, said: "The operation of this assumed and extraordinary jurisdiction is an annoyance to the neighboring states, injurious to the morals and habits of their people; and the existence of it is, for this reason, to be reprobated in the strongest terms, and to be counteracted by legislative provisions in the offended states."'

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