This section is from the book "Popular Law Library Vol12 International Law, Conflict Of Laws, Spanish-American Laws, Legal Ethics", by Albert H. Putney. Also available from Amazon: Popular Law-Dictionary.
"Second: Nor are we, in the absence of express words to that effect, to infer that the legislature of this State intended its laws to contravene the jus gentium under which the question of the validity of a marriage contract is referred to the lex loci contractus, and which is made binding by consent of all nations. It professedly and directly operates on all. To impugn it, is to impugn public policy. And while each country can regulate the status of its own citizens, until the will of the State finds clear and unmistakable expression that must be controlling. 'Where,' says Marshall, Ch. J. (U. S. vs. Fisher, 2 Cranch, 389), 'rights are infringed, where fundamental principles are overthrown, where the general system of the laws is departed from, the legislative intention must be expressed with irresistible clearness to induce a court of justice to suppose a design to effect such objects.
"Our conclusion is, that as the marriage in question was valid in Connecticut, the appellant, Rose Van Voorhis, is a legitimate child of Barker, and as such entitled to share in the estate of the testator.
"The judgment should be reversed and a new trial granted, without costs to the plaintiffs or Sarah A. Brintnall, but with costs to the appellant Rose Van Voorhis and the respondents Ella and Elias, to be paid out of the estate.
"Judgment reversed."
A state or country, however, will refuse to recognize the validity of a marriage contrary to the established policy of the forum4 or against the general standard of morality recognized in civilized countries.
It has also been held in a few cases that where two persons, both domiciled in a state under the laws of which they could not be legally married to each other, go into another state for the purpose of being married and thus evading the law of their domicile, the validity of such marriage will not be recognized when the forum is in the state of the domicile.
 
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