"It is difficult to define with precision what is and what is not extreme and repeated cruelty," an Illinois judge noted in 1882. Throughout the century, some courts acted in accordance with the words of an anonymous author of an 1831 piece in the Carolina Law Journal: "The indurance of partial suffering, from incompatibility of tempers, or vicious habits, among married people is an evil vastly less... than that which arises" from easy divorce. Judicially,...
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