One of the first states to gain a reputation as a divorce mill was Indiana, followed by Illinois, Iowa, the Dakota Territory, and Nevada.
Coverage of the wealthy and the scandalous in newspapers often gave the public the perception that many more people were flocking to divorce mills than actually were.
Newer states and territories in the west often had permissive divorce statutes and shorter residency requirements.
James Kent wrote: ...for many years after New York became an independent state, there was not any lawful mode of dissolving a marriage in the lifetime of the parties, but by a special act of the legislature.
This strictness was productive of public inconvenience, and often forced the parties, in cases which rendered a separation fit and necessary, to some other state, to avail themselves of a more easy and certain remedy.
Before 1850, migratory divorce-seekers were granted divorces in Connecticut, Rhode Island, Vermont, Maine, Pennsylvania, and Ohio.
[2]: 62 Indiana established relatively short time requirements for residency and became a popular destination for divorce in the 1850s, as did Illinois in the 1860s and Iowa in the 1870s and 1880s.
[3]: xii Reputations for being divorce mills were formed more from newspaper accounts and publicity than from statistical evidence.
[4] The ease of divorce in Indiana was criticized by citizens, including clergy and women's rights groups.
[2]: 98 The lenient residency requirement coupled with South Dakota's easier accessibility resulted in it becoming a popular destination for migratory divorces.
[2]: 100 Sioux Falls, South Dakota, as the hub of multiple major railroad lines, became known as the "Divorce Colony".
[4] Nevada's six-month residence requirement resulted in Reno becoming the primary destination for migratory divorce in the early 1900s.
Mail order divorces from Mexico, though sometimes spurious and generally invalid if challenged in an American court, became a thriving business.
Charles had obtained a divorce from Kate in 1892 after living in Sioux Falls for more than 90 days, and then married Annie eight months later.
Hendrix and Williams then married each other and returned to North Carolina where they were charged with bigamy and sentenced to two years in prison.
The court reexamined the case in 1945, with North Carolina arguing that six weeks in a motel did not constitute valid residence, and the court ruled that North Carolina did not have to grant full faith and credit to the Nevada decrees because a genuine domicile had not been established in Nevada.