• In the 18th century, Colonial American legislatures granted these special statutes. In 1816, the House of Burgesses of Virginia granted a divorce to Rachel Robards Jackson, the wife of then President Andrew Jackson, from a former spouse. Mrs. Jackson’s untimely death was attributed to her reaction to the scandal that she had married Jackson before the divorce was procured. Now only state courts have authority to grant decrees of divorce.
— Also termed parliamentary divorce. [Cases: Divorce 5. C.J.S. Divorce § 4.]
