Collateral Attack on Foreign, Ex Parte Divorce Decrees: A Virginia Case

Ten years ago it was reported that a bill had been introduced in the Nevada legislature to grant divorces by slot machine. "The divorce seeker would punch the machine once a day for 42 days, to establish residence, then insert 200 silver dollars. As the divorce popped out of a slot, colored lights would flash, wheels spin, and a jukebox would play America." The bill did not pass. But the liberality of existing divorce laws of Nevada and several other "divorce-mill" States has attracted many divorce seekers from all parts of the country, including Virginia.

The "migratory divorces" so obtained have given rise to difficult Conflict of Laws problems, one of which will be briefly discussed here.