"Another charge made against our divorce laws is that, not being uniform, certain states are being overrun with persons of loose moral character, who seek release from marriage ties. Those who make this charge seem to overlook the fact that persons of loose moral character would not be liable to go to the trouble of leaving their home and state in order to gratify guilty passions. But those who find the marriage tie too galling for endurance and yet who wish to be law-abiding citizens presumably, will take advantage of liberal, enlightened, and humane laws, framed with a view to increase the happiness of the people rather than made in such a way as to foster immorality and enforced prostitution." [740] According to the method of determining the amount of interstate migration for the purpose of securing divorce suggested by WILLCOX, "A Study in Vital Statistics," _Pol. Sci. Quart._, VIII, 90-92. [741] DIKE, "Statistics of Marriage and Divorce," _Pol. Sci. Quart._, IV, 608-12. [742] See Streitwolf _v._ Streitwolf (1900), _Opinions of U. S. Supreme Court_, No. 13, p. 553, involving a decree of divorce granted in North Dakota to a resident of New Jersey; Bell _v._ Bell (1900), _ibid._, 551, voiding a similar judgment secured in Pennsylvania by a resident of New York; and S. _v._ Armington (1878), 25 _Minn._, 29-39, in which a divorce granted in Utah to a resident of Minnesota in 1876 was declared void for want of jurisdiction. Similar decisions, involving the notorious fraudulent divorces obtained in Utah before the change of the law in 1878, "have been reached in criminal trials in New York, Indiana, and Iowa, and in civil suits in Massachusetts, Kansas, and Tennessee"--the earliest in 1877: WILLCOX, "A Study in Vital Statistics," _Pol. Sci. Quart._, VIII, 86 n. 1.