In general, on all these provisions, see also _Code of Md._ (1888), I, 143, 144; _Rev. Civil Stat. of Mo._ (1899), I, 742, 743; _Code of Ga._ (1896), II, 230 ff.; _Ann. Code of Miss._ (1892), 420; _Digest of Ark._ (1894), 681 ff.; _Ann. Stat. of Ind. Ter._ (1899), 325-27; _Stat. of Okla._ (1893), 875 ff.; WILSON, _Stat. of Okla._ (1903), II, 1119-28; _Kentucky Stat._ (1903), 846-51; _Rev. Stat. of Ariz._ (1887), 374, 375; _ibid._ (1901), 814, 815; _Rev. Stat. of Fla._ (1892), 505, 506; _Rev. Civil Stat. of Tex._ (1888), I, 886-88. Finally it must be noted as a matter of regret that in no instance in these states has any provision been made for the registration of divorces or the return and publication of divorce statistics. III. THE MIDDLE AND WESTERN STATES[346] [346] In this section are analyzed the statutes of the following twenty-six states, districts, and territories: Alaska, California, Colorado, Delaware, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Montana, Nebraska, Nevada, New Jersey, New York, North Dakota, Ohio, Oregon, Pennsylvania, South Dakota, Utah, Washington, Wisconsin, and Wyoming. _a_) _Legislative divorce._--An examination of the session laws reveals the fact that legislative divorce has at some time existed in many western commonwealths. During the territorial stage, in particular, and in some cases for a considerable period thereafter, the assemblies at each meeting were called upon to hear and determine petitions for dissolution of marriage which ought to have been relegated to the courts. Such, for example, was the practice in Michigan until 1837, when it was forbidden by the first constitution of the state;[347] and in Illinois until a later time. At the session of 1817-18 the assembly of Illinois Territory granted relief to Elizabeth Spriggs because she had been "shamefully abandoned" by her husband, who, it is alleged, is still guilty of "shameful" misconduct, and because she must be "considerably injured if she cannot obtain a divorce sooner than in the ordinary way."[348] Other cases occurred from time to time;[349] and in 1831 the marital bonds of twenty couples were dissolved by one act of a few lines.[350] Indiana appears to have been nearly as indiscreet. For instance, in 1838 the marriage of John Duvall and Nancy Duvall, _alias_ Nancy Stack, was declared null and void.[351] Two years later occurred a divorce from the bond of wedlock, the wife being permitted to resume her maiden name. Thereafter it became the practice in this state for the assembly to grant persons leave to file bills in the courts in cases where the prescribed causes for divorce by judicial process did not exist. Thus in 1842 Mary Ann Bruner was allowed to file a petition because of "her disability by reason of her husband not having absented himself from her for two years," the full term necessary to constitute a valid ground according to the statute.[352] Until 1851, when the