[543] STOVER, _Code of Civil Proced._ (1892), II, 1640.
[544] _Rev. Stat. of Del._ (1893), 598; being the act of 1891: _Laws_, XIX, chap. 243, p. 480.
[545] _Rev. Stat. of Del._ (1893), 598. "In all other cases a divorce decreed in any other state or country" is valid: _ibid._, 598.
[546] _Gen. Stat. of N. J._ (1896), II, 1273; being act of March 7, 1889: _Pub. Laws_, 48. This law has existed in nearly the same form since 1820: see act of Feb. 16, 1820: _Laws of the State_ (1821), 667.
[547] _Gen. Stat. of N. J._ (1896), II, 1273; being act of May 11, 1886: _Pub. Laws_, 345.
A term of twelve months' previous residence was established by Indiana in 1831.[548] This was increased to two years in 1838, regardless of the place where the alleged cause of divorce occurred.[549] A period of one year was again adopted in 1849.[550] Three years later the law was still further relaxed by making _bona fide_ residence in the county of the action sufficient to warrant a petition.[551] In 1859 the one-year term was once more restored,[552] only to yield in 1873 to a _bona fide_ residence of two years in the state and six months in the county; and this provision is still in force.[553] The legislation of Michigan shows similar vicissitudes. The act of 1819 allows an absolute divorce for adultery when the parties are "inhabitants" of the territory, or when the marriage was solemnized therein, and the injured person is an actual resident at the time of the offense and at the time the complaint is filed.[554] In 1832 a residence of three years was fixed for the plaintiff in both full and partial divorce;[555] but in 1838 the term was reduced to two years, and to half that time in 1844.[556] The period of one year is still sanctioned when the cause of action occurs within the state. By the careful act of May 26, 1899, no decree of divorce will be granted in any case unless (1) the plaintiff has resided in the state for one year preceding; or (2) the marriage sought to be dissolved was solemnized in the state and the plaintiff has since resided therein to the time of the petition. Furthermore, in no case will a decree be granted unless (1) the defendant is domiciled in the state when the petition is filed; or (2) was so domiciled when the alleged cause for the action arose; or (3) when he voluntarily appears at the trial, or is brought in by publication, or has been personally served with process or notice. On the other hand, when the cause of action occurs outside the state, a divorce will not be allowed unless the complainant or the defendant shall have resided in the commonwealth for two years immediately before the filing of the petition. If the defendant is not domiciled in the state at the time of commencing the suit, or when the alleged cause arose, before a decree will be granted the complainant must prove that the parties have actually lived and cohabited together as husband and wife within the state, or that the complainant has there resided in good faith for the two preceding years.[557]