According to the sixteenth-century reformer, divorce is the "medicine" for the disease of marriage. It is so today in a sense more real than Smith or Bullinger ever dreamed of; for the principal fountain of divorce is bad matrimonial laws and bad marriages. Certain it is that one rises from a detailed study of American legislation with the conviction that, faulty as are our divorce laws, our marriage laws are far worse; while our apathy, our carelessness and levity, regarding the safeguards of the matrimonial institution are well-nigh incredible. Indeed, there has been a great deal of misdirected and hasty criticism of American divorce legislation. Even thoughtful scholars sometimes indulge in the traditional arraignment. The laws of the American states produced since 1789, declares Bryce, present "the largest and the strangest, and perhaps the saddest, body of legislative experiments in the sphere of family law which free self-governing communities have ever tried."[777] Such sweeping assertions are in many ways misleading and fail to advance the solution of the divorce problem. There is, of course, in the aggregate a "large" body of statutes; for each of the fifty-three commonwealths, on this subject as on all others, has a separate code; but the harm resulting either from the bulk or the perplexity of the laws, while needing a remedy, is not so serious as is commonly assumed. More and more in their essential features the divorce laws of the states are duplicating each other; and there is already ground for hope that in reasonable time they may attain to practical uniformity. Furthermore, it may well be questioned whether the complexity or the conflict in the American codes is so pronounced as in the numerous systems of divorce law maintained in the states of the German Empire until the enactment of the imperial code of 1900. In some cases in German lands the law was obscure and well-nigh past finding out. Prussia alone had three different systems; and Bavaria was in the same plight.[778] If American legislation is on the average more liberal in extending the enumerated grounds of divorce, it would surely be rash to assume that it is the "sadder" on that account. The question is: Has American social liberalism, in this regard as in so many other respects, increased the sum of human happiness? Besides, "laxity" in this connection is not exclusively a feature of American legislation. It may be reasonably doubted whether any "omnibus clause" in the country gives wider discretion to the court than the fourth of the five causes sanctioned by the new uniform law of Germany, allowing divorce when "either spouse has been guilty of grave violation of the obligations based on the marriage or of so deeply disturbing the marital relation through dishonorable or immoral behavior that the continuance of the marriage cannot be expected from the other."[779] Even broader provisions formerly existed in the codes of some of the separate German states, and may