Marriage and divorce give rise to our most perplexing legal difficulties. This is partly due to social considerations. A primary cause, however, can be found in the States' Rights Doctrine as a consequence of which there has been constant confusion and a lack of uniformity in our laws. Our various states differ on when people may marry; whom they may marry; the ages at which they may marry; the residence requirements for divorce and the grounds for divorce. Thus, despite the Full Faith and Credit Clause in the United States Constitution, the decrees obtained in one state are not necessarily recognized by the courts in other states.
Samuel H. Silbert, Random Thoughts on Marriage and Divorce, 4 Clev.-Marshall L. Rev. 91 (1955)