Evening star., 1895-04-27

49, iS ought to be warned
II that they run a good
many chances when they marry foreigners.
Marriages that are considered perfectly
good here may be upset abroad and de-
clared invalid on all sorts of grounds. If
Count de Castellane had welded Miss Anna
Gould without previously obtaining the
consent of his father the union would not
hold good in French law. Similar restric-
tions would follow the citizens of certain
other countries wherever they go. Bava-
ria and Wurtemburg have gone so far as
to forbid their subjects 10 marry abroad
without consent by the home government.
An old English law declared that no de-
scendant of George II should be permitted
to marry at all without having obtained
the approval of the reignlng sovereign.
This regulation, which now covers a great
number of persons, still holds in Great
Britain, though 1t has been eVaded in
number of instances by such descendants
who have had the ceremony performed on
the continent. Laws of a like nature are in
force in several of the states of Germany.
There is little trouble when an
American girl marrieS an EnglShman. The
ceremony, if performed in this country
according to local law, is, a rule, valid
in England. and the converse of this prop
ostion also applies. So Miss Letter is all
right in any event. But supposing such
calamity the death of Mrs. Curzon, her
husband, even If he should so desire, could
not come to America and wed her sister.
At all events, such a union. though stand
ing good here, would not be valid in Great
Britain, where brothers-in-law and sisters
in-law are forbidden to marry each other.
The same law governs in Germany. The
general principle is that no person shall
be allowed to evade the matrimonial regu-
lations of his own country by going some
where else to be married.
The whole question of international mar
riages is complicated by differences in the
codes of nations relating to morality. In
England union between brother-in-law
and sister-in-law Is regarded from the legal
point of view as incestuous, while in Amer
lea it is quite otherwise. In many countries
of Europe marriages of ecclesiastics are
prohibited whereas here they are perfectly
good, no matter whether the ceremony has
been performed in this country or abroad.
Marriages between Christians and Jews
are valid in the United States. but not so in
Austria and Hungary. Until recently
similar interdiction prevailed in Prussia.
The laws of the United States would only
recognize one of the plural wives of polyg
annie Cinnamon or East Indians.
Legation Marriages.
Americans are frequently married at le-
cations of the United States in various
countries abroad. 1t is a highly objection
able practice, and our government disap-
proves of it. The notion at the bottom of
it is to the effect that an American lega-
ton is American soil and that on such soil
marriages conducted in accordance with
United States laws are good. There is just
enough truth in this idea TO lead people
into mischief. 1t is true that United
States legation is bit of United States
soil, but that proposition does not affect
the fact that marriage in any civilized
country, in order to be valid, must be in ac-
cordance with the laws of that country. In
an uncvilized country it is different. There
the only laws to be considered those of
the country where the contracting parties
claim citizenship.
Great Britain does recognize marriages
of her citizens performed a her lega-
tions abroad. But here the case is some
what different. The Church of England is
a recognized part of the state and is rep
| resented at every legation by a chaplain
who is a public official in a sense. He acts
as an agent of the government in perform
ing such ceremonies. But even marriages
thus accomplished are admitted to be not
necessarily valid in other countries, though
all right in Great Britain. Obviously 1t is
hardly possible to make such matters too
sure. Under date of August 81 1874, Mr.
Hoffman. secretary of our legation at
Paris wrote to the Department of State at
Washington saying that during the pre-
vious seven years $50 marriages of Ameri-
cans had taken place at the legation-a
greater number probably than in all other
legations of the United States during the
same period He remarked that, inasmuch
as these marriages had not complied with
the laws Of France. there was serious dan
ger that their legality might be disputed
Massachusetts has declared that mar
riages Of her citizens at our legations in
foreign parts are good but she cannot
make them valid in France. 1t goes with
out saying that a married woman ought to
be wife in all countries. Congress has
| made a declaration similar to that of Mas
sachusetts just quoted but it can only be
held to apply to citizens of the District of
Columbia and the territories. We have no
national marriage law, and the regulations
of each state of the Union respecting mar
riage and divorce are supreme so far as
it's own citizens are concerned
A Diversity of Laws.
Not long ago the Department of State
issued a circular to our diplomatic and
consular representatives abroad, express
ing disapproval of the practice, commonly
observed by such officials, of giving to
parties wishing to be married certificates