sanctioned the same doctrine. In Jewell _v._ Jewell,[632] considered in 1843, opinions on the question were evenly balanced, just as they were in the Queen _v._ Millis which came before the Lords during the next year; but in 1877, in the case of Meister _v._ Moore,[633] involving a marriage contracted under the law of Michigan, Justice Strong adopted "as authoritative" Judge Cooley's interpretation rendered two years before. [606] In the case of Fenton _v._ Reed (1809), 4 JOHNS., 52; 4 _Am. D._, 244; EWELL, _Cases on Domestic Relations_, 397-99. Following are the essential facts in this celebrated case. In 1785 John Guest "left the state for foreign parts." During his absence, in 1792, his wife Elizabeth married Reed. Subsequently in the same year her first husband, Guest, returned to the state and there resided until his death in June, 1800. He professed to have no marital claim upon Elizabeth; so she lived with Reed as a wife continuously from 1792 until the latter's death in 1806. Was she the lawful wife of Reed from 1792 to 1800 during the lifetime of Guest? If not, was she, without the observance of any formalities, his lawful wife from 1800 to 1806 after Guest's demise? To the first question the court answered "no," holding that "the statute concerning bigamy does not render the second marriage legal, notwithstanding the former husband or wife may have been absent above five years, and not heard of. It only declares that the party who marries again in consequence of such absence ... , shall be exempted from the operation of the statute, and leaves the question of the validity of the second marriage just where it found it." To the second question the court answered "yes," as explained in the text. _Cf._ Starr _v._ Peck, 1 HILL, _N. Y._, 270. [607] 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. [608] See Fryer _v._ Fryer (1832), RICHARDSON'S _Equity Cases_, 92 ff. _Cf._ the case of Vaigneur _v._ Kirk (1808), 2 _S. C. Equity Reports_, 640-46; and 10 MCCORD'S _Statutes_, 357, ed. note; _ibid._, II, 733, ed. note. [609] Holmes _v._ Holmes (1833), 6 _La._, 463. In this state, under influence of French and Spanish law, the common-law contract appears always to have been regarded as valid. [610] Askew _v._ Dupree (1860), 30 _Ga._, 173; _cf._ Clark _v._ Cassidy, 64 _Ga._, 662.