marriage.[671] A glance at the facts collected in the sixteenth chapter will show that in some states the license must be secured in the place of the bride's residence; in others, in that of the marriage; while in a third group it may be issued in the place where either dwells. Indeed, Pennsylvania, more liberal still, allows a choice among all three places. The same laxity exists regarding the place of return; and sometimes the place of return is not the same as that of issue. A reasonable term of residence ought always to be required; and, unless in cases of emergency, the license should be issued by, and return made to, the same official in the district where the woman dwells. Even the lack of uniformity in license fees is sometimes the cause of migration to neighboring districts for the sake of cheaper weddings.[672] Finally, a marriage entered into without license, just as without authorized celebration, should be declared null and void by the statute. [666] In "Diagnostics of Divorce," _Jour. of Soc. Sci._ (Am. Assoc.), XIV, 136, PROFESSOR ROBERTSON takes the extreme view that "no person should be marriageable under the age of 21, and a marriage ceremony celebrated between persons either of whom is under age should be _ipso facto_ void." [667] Neither in England nor anywhere in the United States is a marriage declared void for want of parental consent. The leading case on the point is Parton _v._ Hervey, 1 GRAY, 119. "Some years ago a young girl, only thirteen years of age, named Sarah Hervey, was enticed away from her widowed mother's house by a young fellow, named Parton, of bad character and dissolute habits, who by false representations as to the age of the girl, procured a marriage license, and persuaded a magistrate to formally marry them. She returned to the house of her mother who forbade the young man to see her. Upon his petition against the mother for writ of habeas corpus, the Supreme Court of the Commonwealth, after full consideration, ordered the young wife to be surrendered to the husband, and he bore her away in triumph.... The mother then brought suit against a confederate of the husband, who had aided in enticing away the girl and in practising the fraud upon the magistrate; but the mother again failed in her efforts to vindicate her rights to protect her daughter, since it distinctly appeared that the marriage was with the daughter's full and free consent."--Hervey _v._ Moseley (1856), 7 GRAY, 449; as summarized by BENNETT, "Uniformity in Mar. and Div. Laws," _Am. Law Register_, N. S., XXXV, 222. [668] _Laws of N. H._ (1903), 79. [669] Louisiana formerly had a law requiring notice of intention to be filed fifteen days before issue of license; but it appears to have been repealed. In Porto Rico the period of delay is ten days. [670] As suggested by COOK, "The Mar. Cel. in the U. S.," _Atlantic_, LXI, 687.