Tuesday, July 31, 2012

The Right to Marry

Even if you're the straightest, whitest, most Christian couple in the entire state of Louisiana, you don't have the legal right to marry. Not really.

It's not that you lack the right to conduct a government-approved ceremony and obtain the legal status of a married couple; you can do that. You can even file your federal tax returns as a married couple, as long as you don't have matching genitals. But nowhere in the United States do you have the right to credibly contract for a lifetime marital partnership.

Every state currently allows some form of "no fault" divorce - divorce not based on any wrongdoing of a party, but simply because the parties claim they don't want to be married anymore. Even though the couple may "vow" to remain together until one of them dies, everyone knows these vows have no legal or real-world effect. The marital "contract" is not a contract at all.

Imagine a regular legal contract in which either party could end the agreement by saying he didn't like it anymore. Could the purposes of contract law be served by such a contract? From a law and economics point of view, such an "if-I-feel-like-it" contract would not support the reliability of contracts, and would require an inefficient level of hedging. The legal term for such a contract is an illusory contract - one that doesn't have any legal effect, of which the legal system will take no notice.

Marriage once did have a legal effect - once married, parties could not divorce without a really good reason (physical cruelty, desertion, or adultery). Not coincidentally, marriages were much more likely to be reliable lifetime partnerships. In addition to the legal strictures surrounding marriage, social groups essentially forced couples to stay together or risk social death.

With the nationwide adoption of no-fault divorce and the elimination of the social stigma of divorce, the nature of marriage changed from a genuine contract to an illusory contract. Marriage stopped being the reliable, socially enforced lifetime partnership it had been for generations.

Poly people might be tempted to think of the destruction of socially enforced monogamy as a good thing. Indeed, many people who did not really want to marry were no doubt forced to do so, and forced to stay married, because attractive options did not exist.

However, even poly people must on reflection realize that an important right has been lost: the right to reliably, credibly commit oneself for life. Even those who think polyamory is the best choice for them rarely want to force their lifestyle on others; indeed, they are often some of the most vocal supporters of expanding the right to marry to gay people. Sadly, however, in allowing anyone the right to divorce at will, we have deprived everyone of the right to truly marry.

Sensing that marriage is now an empty institution, some couples have specifically contracted for the rights marriage traditionally gave them (but no longer does). In the California case Diosdado v. Diosdado, 97 Cal.App.4th 470, a husband and wife contracted that if the husband had an affair with another woman, he would pay the wife $50,000 on top of the divorce settlement, and vice versa. The husband did in fact have an affair, but the California court refused to honor the couple's agreement. The strong California public policy of no-fault divorce, the court said, prohibited courts from even enforcing the voluntary contracts of a mature adult couple:

The family law court may not look to fault in dissolving the marriage, dividing property, or ordering support. Yet this agreement attempts to penalize the party who is at fault for having breached the obligation of sexual fidelity, and whose breach provided the basis for terminating the marriage. This penalty is in direct contravention of the public policy underlying no-fault divorce.

That's right: in California, as in other states with a strong no-fault public policy, you can't even voluntarily make a credible promise of marriage and expect it to be honored by the courts.

A few states - Lousiana, Arizona, and Arkansas - allow what is called "covenant marriage," marriage that may only be dissolved on fault grounds. However, couples may not even use covenant marriage to credibly promise lifetime partnership, because either partner may simply relocate to a non-covenant-marriage state and initiate no-fault divorce proceedings there.

To recapitulate, no one in our country truly has the right to marry, in the sense of committing oneself to a partnership for life. It is legitimate to wonder if this deprivation of rights has caused the proliferation of both tattoos and ludicrously expensive wedding ceremonies, as a last-ditch effort for permanence.

Not even mature adults of sound mind, after long reflection, may decide to marry for life. However, there is another right that has been found to be so fundamental that it cannot be taken away, even from those who have demonstrated that they will abuse the right: the right to breed. The right to have children, like the right to marry, is not mentioned in the Constitution, but is interpreted as protected by the implied right to privacy. However, unlike the right to marry, the right to breed has been genuinely preserved. Mothers who starve their children to death, Trammel v. State, 751 N.E.2d 283 (Ind. Ct. App. 2001), and fathers who make no effort to support their children, State v. Talty, 103 Ohio St.3d 177 (2004), may not be restricted in their "fundamental right" to have as many children as they can.

It is sad for all of us that the law protects the right of each person, no matter how cruel or stupid, to create new, needy, suffering human beings; but no person, no matter how mature, is trusted with the right to credibly commit him- or herself to marriage for life.

60 comments:

  1. Until the second-last paragraph, I was wondering what point you might have been getting at.

    I find these "right to have children" and "right to marry" distinct enough that I think this is a non-sequitur. In any case I don't think anybody should have either of these rights! The former almost unconditionally, and the latter until neuroscience advances to the point that it can reliably predict indefinite mutual love (and even then exceptions should be made for brain damage occurring during a marriage).

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    1. Glad I'm preaching to the choir in your case re: breeding. As for marriage, I think a few things are relevant, especially for consequentialist-leaning types:

      1. Happiness studies consistently show large happiness effects from marriage. Married people are happier than single people; married parents are MUCH happier than single parents.
      2. Divorced people take a major happiness hit; they are less happy, on average, than people who never married.
      3. Marriage may be ESPECIALLY important for tribeless moderns, who have fewer social bonds to rely on - obligatory moves for college and work, etc.

      It has become somewhat taboo to suggest that being a single parent is a bad thing. Studies on outcomes from single versus partnered parents tend to find little difference - when they control for things like income. But, of course, marriage directly affects and is affected by just those variables - income, education, neighborhood, etc.

      You're definitely not the only one who found this a "non sequitur" - and that response surprised me. Marriage and children don't seem related to modern people! Wow!

      In addition to observation and common sense that single parenting sucks both for the parents and for the kids (NYT piece), there's another datum I find important: parental rejection seems to be a significant predictor of bad personality outcomes.

      What I'm emphasizing here is that while our governments and societies don't trust us with the right to choose a romantic partner for life and commit to that decision, they trust even the stupidest among us with the right to create children, something that will negatively affect our own happiness and bind our actions for years, if not life. But lifetime marriage isn't only a right we ourselves are deprived of; those children we're entitled to create are deprived of the ability to benefit from a credibly contracted lifetime parental partnership.

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    2. "the latter until neuroscience advances to the point that it can reliably predict indefinite mutual love"

      Do you think we need a standard this high to make allowing marriage a net positive? It's possible, but far from obvious, at least if we're talking about lives of a few decades (maybe you're not). (Or do you think the costs of bad marriages should be given far more weight in deciding policy, or something else?)

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    3. "Divorced people take a major happiness hit; they are less happy, on average, than people who never married."

      Sure, but that's not really the right comparison. In the absence of no fault laws, I bet the majority of divorced people still would have gotten married. So happiness among never married folks aren't really counterfactuals for happiness among divorced folks, even if you control for a bunch of variables. I think research on happiness related to marriage and religion suffers from many of the same problems as research on diets.

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  2. Interesting observations that there's no "right to marry" in the sense of total lifelong commitment without an option for unilateral dissolution or even a bilateral no-fault dissolution.

    But look at this way: By marrying you give up a lot of rights and freedoms, which you can only regain by divorce. In a "covenant marriage", you have no way to regain those rights, giving them up permanently.

    Even so, before no-fault divorce was legal, many couples would create legal fictions around adultery or cruelty to obtain an at-fault divorce from the court. Generally the husband played "at fault". So bilateral divorce was possible with the married couple jointly deceiving the state. I suppose unilateral divorce is possible by fault (very costly and not even reliable), or manipulating your partner into fault and then suing for divorce. The most you could say is that there was no honest way out of marriage before no-fault divorce.

    Meaning, what we have now is a state where you don't have "the right to permanently give up your rights" (barring using deception to get them back). I think that's a good thing.

    It's in-line with a long tradition in which individuals have less and less been able to sign away their rights and freedoms and protections. For example, indemnity forms that sign away one's right to sue for damages caused by gross negligence, are now widely unenforceable.

    On the other hand, corporations and other legal persons can sign away pretty much all of their rights. In a sense, natural persons are treated by law as less competent than legal persons, and given a bit of paternal state protection against their own foolishness.

    The post did not segue well into the "right to breed" paragraph - it reads as an apples-to-oranges comparison. Probably would be better as a separate post, with space to draw out the analogies you want to make.

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    1. When you say "no right to give up rights" is a good thing, how do you mean that? Good, on average, for happiness? Or good even though it reduces happiness?

      I see the suicide question in similar terms: the right to commit suicide is the right, essentially, to give up future rights. Non-suicidal people might think it's a great thing to be forced to not give up future rights; but suicidal people see that being forced to "keep" your future rights is a major welfare hit. Similarly, I have only thought of marriage in these terms since being in a serious monogamous relationship for the past year with an intellectual equal.

      Completely agree that natural persons are deprived of rights out of paternalism. That's my point: paternalism prevents real marriage, but it's hands-off with BREEDING, which has much more serious consequences both to the parents and to the children. If there's paternalism for marraige, it should apply doubly to breeding.

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    2. You want the right to give up future rights (covenant marriage, suicide).. but how do you want to handle human fallibility? People make mistakes. Some people really do know, for sure, that they want a lifelong covenant marriage, but many people change their minds later. Exhibit A: the many couples who perjured themselves in the early-to-mid 20th century get around the lack of no-fault divorce.

      Similarly, some people really do know, for sure, that they want to die, but many people change their minds later. If those people were permitted legal suicide now, they could not change their minds due to being dead.

      What then do you propose?

      I think the special treatment for breeding is due to its status as a primary biological function. In most people's eyes, placing conditions on the right to breed is like placing conditions on the right to breathe. Right or wrong, that's how it's perceived.

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  3. Culture is upstream from the law (and one may add, biology is upstream from culture). Given this, the solution to the modern impossibility of a lifetime marriage bond is not to fixate on no-fault divorce, or even the 'right to marry', but to consider the conditions which allow for social enforcement of the marriage bond and of bonds in general.

    Those conditions originate in a cultural sense of the sacred, which created taboos and invested divine authority in the law, without which it had no power. Sadly, the disenchantment of the world which has proceeded under the guise of progress has effectively banished the possibility of returning to the sacred and ergo a time when the marriage bond was enforceable in any real sense, and so there is actually no present available solution. Enjoy liberal individualism while it lasts (not long).

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    1. Absolutely agree. As I often say, we are better at poking holes in sacred bullshit than at building sacredness structures that can support our happiness and flourishing. I doubt that a return to fault-based divorce would work, since we have also lost the sense of sacredness of marriage, and also the traditions for making good marriage choices.

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    2. I realise this thread is old, but the only solution is for men to go on marriage strike. If they should "marry" at all, it should what the courts (in the UK, at least) would describe as a "non-marriage" — i.e. it does not satisfy the legal requirements to be a civil marriage.

      It can be a ceremony, it can involve vows, it can involve a change of surname, it can involve referring to and regarding each other for all intents and purposes as husband and wife; but it will not be a marriage at law. This is the only viable way to be "married" and avoid punitive divorce laws.

      This already, sort of occurs with the rise of commitment ceremonies, and religious people should find this attractive because they can be married in the eyes of God — the only approval that ultimately matters to them — while cutting out the state. Indeed, Muslims in the UK who only marry in their mosque are in "non-marriages" unless they marry civilly as well. Christians ought to consider this option too.

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  4. "It is legitimate to wonder if this deprivation of rights has caused the proliferation of both tattoos and ludicrously expensive wedding ceremonies, as a last-ditch effort for permanence."

    No need to wonder. There is Evopsych consensus that costly weddings have usurped at least one of the functions of the older 'bride price' custom -- namely, as a disincentive to separation.

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  5. Talk about freedom of contact.

    This issue reminds me of the omnipotence paradox. We're not "all that powerful" if we can't give away some rights.

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    1. So should we also be able to give away the right to commit suicide?

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  6. Sister Y,

    Curious: Do you think the same-sex marriage movement would have happened without no fault divorce?

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    1. I don't know. I think there's a much better case to be made for gay traditional marriage than for stupid modern fake marriage excluding gays, but I'm a brainwashed liberal bisexual so it's hard to sort out.

      There's that Mormon gay guy who is out but has a monogamous Mormon wife and kids. That seems to work for some people.

      I have a harder time seeing how allowing gay people to marry would harm marriage, but I find it easy to see how allowing people to divorce at will effectively destroys everyone's ability to marry. Thoughts?

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    2. If you're wondering how gay marriage would harm hetero marriage you're asking the wrong question -- the debate over gay marriage has nothing to do with whether 2% of 2% of the general population gets to play 'house' within a government-affirmed legal contract. There is effectively no actual consumer demand for gay marriage qua gay marriage.

      Instead, like no-fault divorce, the brouhaha over gay marriage is merely a symptom of a cultural transition, which to some appears as a declension and to others appears as a step forward in history (I prefer the former). Conservatives are terrible at distinguishing causes from symptoms, which often results in asinine culture war rhetoric, but liberals fare hardly better.

      The reality is that monogamous life-term marriage is no longer theoretically feasible within desacralized, modern mass society. It persists solely out of inertia. Many people sense this, which is why they have become (perhaps irrationally) hostile to phenomena which seem to signal greater desacralization, of which gay marriage is merely one example.

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    3. Sister Y,

      I agree with you and have made the same points in conversation from time to time. I also think there's strong evidence that the out-of-sight poor have been especially hard hit by liberalized divorce law and attendant cultural changes that took root in the 60s and 70s. The argument is made forcefully in Charles Murray's "Coming Apart" by reference to longitudinal data showing that while middle and upper-middle class people have largely bounced back from the first wave of liberalized divorce, poor people are now more likely than ever to split up, or never get married at all. I know a lot of people think this is not a big deal, but a lot of people, as Murray points out, live in bubbles. None of it would matter were there not good reason to believe that traditional marriage provides many people with a sense of meaning and well being that would otherwise not be available, but I think it wise to consider that the disintegration of the institution could have been harmful in ways that are too readily dismissed by liberal intellectuals.

      I asked the question I asked because the best argument against gay marriage that I've heard goes something like this: Since marriage has already been severely undermined by "no fault" precedent and by the removal of the stigma that once attached to divorce, the specter of same-sex marriage may be the final straw that removes whatever remaining value the institution has for those who stand to benefit from it. From a certain vantage (which I generally share), it is easy to scoff at this type of argument, but just because something seems silly or offensive to "enlightened" people doesn't mean that the negative effects aren't real.

      I should make clear that I have no moral problem personally with same-sex marriage, and I think it follows under equal protection jurisprudence. At the same time, I grew up thinking of homos -- at least gay men -- as cultural outlaws, so it seems odd to see this emerge as the civil rights issue of our age. It's like if Harry Callahan turned in his badge and began a second career as a gun control lobbyist.

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  7. "Imagine a regular legal contract in which either party could end the agreement by saying he didn't like it anymore."

    Do states (all or any) allow unilateral no fault divorce? That seems like a really bad idea, but I didn't think that was the case. If it's only bilateral no fault divorce that's at issue, it's more difficult. I'm not a lawyer, but my understanding is that it is generally acceptable, when all parties agree, to make changes to earlier contracts. Are some contracts unalterable? If so what are the legal conditions that determine when an unalterable contract can be made and/or enforced, and what is the mechanism for enforcement?

    I can see the value of making unconditional irrevocable commitments. Indeed, there is a large literature on time inconsistency which suggests that there is such a value. But to what extent has the law ever (outside of marriage itself, before there was no-fault divorce) made provision for such unconditional irrevocable commitments? And to the extent that it ever has, outside of institutions like marriage in which there was a social stigma associated with violating the commitment, how could such commitments ever be enforced if there was no criminal activity involved? Who would sue someone for breaking an agreement that they also preferred to break?

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    1. California and MANY other states allow unilateral, no-fault divorce.

      Some states technically allow only bilateral no-fault divorce, but in practice, if one spouse doesn't want no-fault and demands to stay married, the courts bend over backwards to find grounds to grant the divorce on a fault basis. I've seen a case from one of the Dakotas where the husband won't consent to a no-fault divorce, and the court grants a fault-based divorce on cruelty grounds to the wife essentially because the husband is a Jehovah's Witness and tells the kids mom is going to hell.

      Contract law in general allows everyone to break commitments with no penalty as long as they pay for the damage they cause. When parties agree, absolutely they can reform/rescind the contract. But contract law is not very harsh even for breaching parties; they must simply pay for not doing what they promised. Of course, there are reputation effects...at least, there used to be.

      I'm not sure marriage should be treated exactly like a contract; perhaps there should be even more enforcement of marriage. But as of now, marriage isn't EVEN treated as an enforceable contract. It's usually just nothing.

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  8. "an important right has been lost: the right to reliably, credibly commit oneself for life."

    Oh no, I have lost the "right" to be forced to do something in the future without my consent. Whatever will I do? This is a disaster.

    Oh wait... I actually believe in consent as a necessary feature of a free society. Neeeever mind...

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    1. How do you feel about promises in general? Are they morally important?

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    2. Lifetime commitments are pretty hard on future selves... It doesn't seem that the possibility of such commitment in the form of marriage is necessary for society to function, so I think vis-à-vis future people, you'll have a hard time arguing for traditional marriage.

      Promises are different in that they are usually more short-term, and they are in fact needed for social relations to work, I suppose. But I think it's not fair to demand that promises be kept that later turn out to be overdemanding.

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    3. Indeed - but life itself is pretty hard on future selves. What if being forced into traditional marriage makes people happier, on average, than our sorry liberal asses?

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    4. Also the break-ee doesn't consent to being single :(

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    5. "I actually believe in consent as a necessary feature of a free society."

      That's cute. Meanwhile, in the real world, where real people with real problems live, 'consent' is a fiction that many would -- and do -- gladly surrender in exchange for security and happiness. Then there is the question of who or what validates consent, which in the final analysis is whomever or whatever maintains the dominant jurisprudence, and which is something which we did not 'consent' to ourselves.

      Besides, even liberal theorists like Rawls acknowledge the importance of obligation. Once one voluntarily participates in the benefits of a just society, so he argues, one is obligated to yield some measure of consent, just as the founders of that just society yielded their consent for the sake of political cooperation. The analogy to marriage remains to be drawn out here.

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    6. What if being forced into traditional marriage makes people happier, on average, than our sorry liberal asses?

      Then it just depends really on how you feel about paternalism, I guess. I just have pretty strong anti-paternalist feelings, hence my not-quite-thought-out reaction to it.

      Also the break-ee doesn't consent to being single.

      I can't get that voice in my mind to shut up that says "that's their problem". Next we're forcing people to start relationships because of all the poor single people. Wait. We used to do that, didn't we?

      Which, I think, brings us to an important issue: We must distinguish between discussion whether society should be such-and-such and whether we should immediately turn society into one that is such-and-such. Throwing people as they are now into a more traditional society may cause massive suffering, even though the suffering in such a society once it is firmly established with people growing up in the culture and all is lower than what we have now. And the trouble with discussing such things is that your intuitions are inevitably about the former, whereas I think the target of your discussion is the latter.

      On another note, I think the argument for a right to (truly) marry essentially requires a moral theory which doesn't work with the concept of a right, which is kind of ironic. Of course the right to marry you're talking about is legal, so it's not contradictory. But still ironic.

      Needless to say, I agree with your implicit assertion that there shouldn't be a right to procreate.

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  9. So this post points out that there are some features of traditional human society which may be extremely weight-bearing for happiness that have been perhaps irretrievably screwed up by modernity.

    I'm paleo enough to engage in romanticizing the past (plus I grew up on a farm with no electricity or running water, and we grew/hunted most of our food, and it was AWESOME), but let's not forget that the past mostly sucked too, just in different ways.

    We can't go back - for one thing, there are way too many of us to be supported in simple societies; for another, the cultural traditions necessary to support simple societies have not been adequately preserved. But also, simple societies had major disadvantages, like constant violence.

    I do not think human life has ever been so good as to guarantee a good life for a child enough to justify a birth. However, pragmatically, it's interesting to investigate what has changed and how it has affected the distribution and absolute levels of happiness, distress, satisfaction, misery, etc.

    So I want to make it clear that I'm not advocating a "return" to earlier ways of living simpliciter; I do think the possibility of making a lifetime marriage commitment should be a right, perhaps limited in (fair) ways. But marriage doesn't exist in a vaccuum; rather, it's a supporting part of a society-wide, gigantic design problem.

    No one knows how to make a happy, functioning society (though lots of us think we do). The first step toward improving society might be admitting this basic fact.

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    1. "No one knows how to make a happy, functioning society (though lots of us think we do). The first step toward improving society might be admitting this basic fact."

      Agreed. So why are you a liberal?

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    2. 1. It's largely genetically determined
      2. I'm not a very good liberal
      3. Good luck finding smart, interesting friends who aren't liberals (as Razib Khan frequently laments)

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  10. Sister Y,

    What is it exactly that appeals to you about a marriage contract that you would not be allowed to break? Is it the sharing of financial resources? I can see that in the sense that two people who have made a financial decision to share a life together can have a higher standard of living by pooling resources, and maybe feel more comfortable and secure knowing their partner can't just back out at any time.

    Is this mostly your line of thinking here? Outside of financial reasons, what do you consider to be the advantages (from a legal/contract point of view) of such a marriage as what you describe here, as opposed to just a non-legal agreement that you want to share your life with another person? I know some couples that have been together for years and enjoy their lives together even though they are not legally married.

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  11. One thing I can think of, which makes married people -- who have reduced their own freedom -- happier than others is that they can "blame" the marriage / spouse for shortcomings in career or other pursuits. Even if others get to say 'you chose to get married', fact is the married person can at least tell that to themselves and get relieved of guilt.

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    1. I had a friend who stayed in a horrible marriage and he used to say he was glad he just didn't have to think about that aspect of life anymore - like he'd made his choice, and could use his cognitive resources elsewhere. I dont know if that's what you're getting at, or if it was a good choice in his case, but it seems like a serious consideration.

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  12. Given that marriage is an explicit, specific, and public (though perhaps legally unenforceable) commitment between people who presumably know each other well and trust each other, why is individual conscience not sufficient to enforce the commitment on either side? I would suggest:

    1. If you don't trust someone to honor such a commitment, you probably shouldn't be marrying them in the first place.

    2. If your trust turns out to be misplaced, it's probably not in your interest to continue being married to them. (My understanding is that the law still protects, or at least attempts to protect, your critical economic interests, such as avoiding being left with no means of support if the other party had become your only means of support.)

    3. Perhaps people just don't take the commitment seriously, but this is something they ought to discuss before getting married. If it's understood from the start that they do take it seriously, then dictum pactum est, and a unilateral divorce would happen only in one of the following cases:

    a. Both parties have agreed to divorce, but it's more convenient to effect it unilaterally.

    b. One party is highly untrustworthy.

    c. The other party is actually at fault, but it's more convenient not to specify the fault explicitly.

    If people who know each other well cannot trust each other's solemn word, we have bigger problems than the lack of a technology for lifetime commitment.

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    1. (This comment is also party of what I was answering in the new post What Marriage Is)

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  13. It seems you are unhappy with your marriage Sister Y.

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    1. I see personal experience as a springboard for abstract reflection and hopefully insight, rather than reductively explaining positions. But that said, this train of thought was insprired by how fantastically awesome my present relationship is! <3

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    2. Except, I assume, for having to return to the earth's surface several months every year so the crops don't die and winter is replaced by summer.

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  14. What can I say... we are a sad pathetic excuse for a species...

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  15. As a practical matter, even though American divorce is unilateral no-fault, it is "no penalty" only for women. American divorce courts almost invariably penalize men (only) financially and by depriving them of access to children, which is why educated American women initiate divorce nine times as often as men-- the women expect to keep the children and much of the (ex-) husband's money ( http://en.wikipedia.org/wiki/Divorce#Gender_and_divorce ).

    So American men still have the right to make a commitment which they may break only at severe hazard, but women don't; indeed, they are incentivized to make false commitments and breach them for gain!

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    1. Perhaps that is one reason that with the rise of no-fault divorce AND mandatory child support, children now increase the likelihood of divorce. Mercenary and of course no one is "like that," but incentives matter.

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    2. Yes:

      http://www.unc.edu/courses/2010fall/econ/586/001/Readings/Brinig.pdf

      "We have found that who gets the children is by far the most important component in deciding who files for divorce, particularly when there is little quarrel about property, as when the separation is long."

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  16. "Imagine a regular legal contract in which either party could end the agreement by saying he didn't like it anymore"

    Yeah, I sign them all the time. Employment contracts, for instance. They have exit conditions.

    The rest of the post made about as much sense as this

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    1. In fact, an employment contract may be found "illusory" (not a real contract hence not enforceable) if its exit conditions are too broad such that they amount to "if I feel like it."

      But I'm sure an anonymous internet commenter knows better than a lawyer, so carry on! <3

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  21. Wow is good to be back with my ex again, thank you Dr Ekpen for the help, I just want to let you know that is reading this post in case you are having issues with your lover and is leading to divorce and you don’t want the divorce, Dr Ekpen is the answer to your problem. Or you are already divorce and you still want him/her contact Dr Ekpen the spell caster now on (ekpentemple@gmail.com) and you will be glad you did

    ReplyDelete
  22. Getting back together with my ex was a very tough challenge and I failed it many times after my man broke-up with me. but after i read about Kwale Temple love spell and decided to get in contact with him and when he replied my mail I discover it was so easy for me to get my man back within 48 hours. That's how i got my boyfriend back at kwaletemple@gmail.com  whats app him on +2348056141089.

    ReplyDelete
  23. Powerful Effective Love Spell Get Your Ex Back.. About a month ago I got back to my ex(after 2 and half years separated). Everything was ok and she was the most adorable woman in the world. she spoke about the wedding ceremony, how many kids we would have, said that our relationship was the most important thing in her life and he was 100% sure about it…Then he traveled to work in another country for 3 weeks. he changed his behavior completely. he disappeared every night, was saying she had to do some work and would talk to me later, but disappeared the rest of the day and night… no explanation, when I asked why she was disappearing every night, she stopped answering me. she kept ignoring me since, she ignored even my birthday, Not even a message. I wrote to her a few times trying to understand what happened, she read but just ignored me.I feel so bad cause I couldn’t stop contacting and trying to understand what happened.i loved her so much and wanted to get her back, then i was told to contact Dr Azaka who can help out with a love spell to reunite your relationship back, so instantly do contact him and give him a try and trust me he did an urgent effective love spell for me and with 48hours promise he made to me, my woman was back, today i testify to you all that you should seek and contact Dr Azaka for his spell result is genuine sure and guarantee to unite and get your ex back save your marriage/relationship problem now, Contact Dr Azaka Spell temple via Whatsapp +2349059389105 or Email azakaspelltemple@gmail.com

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  24. My husband has stared performing his duties as the man of the house and has also stop drinking recklessly. Am so joyful to tell anybody out there to save his/her marriage problems with Dr Lababa spell through these details. lababasolutiontemple@gmail . com

    ReplyDelete
  25. Hello my name is Belinda i want to share my amazing experience with the greatest spell caster Dr irekenagba. my husband was cheating on me and when i found out we had a fight which lead to him filling for a divorce i cried and fell sick when i was searching about love quotes online i saw people talking about him and his great work whose case was similar to mine they left his contact info i contacted him and he told me not to worry that after 24hrs he will cancel the divorce and be back to me after i did everything he asked me to do to my greatest surprise the next day evening it was my husband he knelt down begging me to accept him back,thank you once again Dr irekenagba you are indeed a blessing to me he can also help you contact him on........
    WhatsApp: +2347059630655
    email:doctorirekenagba@gmail.com

    ReplyDelete
  26. Hello my name is Belinda i want to share my amazing experience with the greatest spell caster Dr irekenagba. my husband was cheating on me and when i found out we had a fight which lead to him filling for a divorce i cried and fell sick when i was searching about love quotes online i saw people talking about him and his great work whose case was similar to mine they left his contact info i contacted him and he told me not to worry that after 24hrs he will cancel the divorce and be back to me after i did everything he asked me to do to my greatest surprise the next day evening it was my husband he knelt down begging me to accept him back,thank you once again Dr irekenagba you are indeed a blessing to me he can also help you contact him on........
    WhatsApp: +2347059630655
    email:doctorirekenagba@gmail.com

    ReplyDelete
  27. Hi everyone,I’m so excited my husband is back after he left me for another woman. My husband was having an affair with a co-worker and i love my husband so much but he was cheating on me with his co-worker and this girl i think she use witchcraft or black magic on my husband to make him hate me and this was so critical and uncalled-for, I cry all day and night for God to send me a helper to bring back my husband! I was really upset and i needed help, so i searched for help online and I came across a website that suggested that Dr.Wealthy can help get ex-boyfriend back fast. So, I felt I should give him a try. I contacted him and he told me what to do and i did it, then he did a love spell for me. 22hours later, my husband really called me and told me that he miss me so much, Oh My God! i was so happy, and today i am happy with my man again and we are joyfully living together and i thank the powerful spell caster Dr.Wealthy, he is so powerful and i decided to share my story on the here. if you are here and your Lover is turning you down, or your husband moved to another woman, do not cry anymore, contact Dr.Wealthy for help now..Here’s his email, wealthylovespell@gmail.com
    He also do the following spell
    Pregnancy spell
    Love spell
    Penis enlargement spell
    herpes/hiv
    Winning spell
    His email, wealthylovespell@gmail.com
    Or his WhatsApp +2348105150446

    ReplyDelete
  28. I just want the whole world to know about this spell caster I met
    two weeks ago, wisdomspiritualtemple@gmail.com I cannot say everything he has done for me my wife
    left me 3 years ago left with my kids I was going through online
    when I meant this wonderful man's testimony online I decided to
    give it a try and my wife is back to me now and we ar1e happily
    married again cause is too much to put in writing all I can say is
    thank you very much am very happy .and does alot of spell
    including Love Spell
    Death Spell
    Money Spell
    Power Spell
    Success Spell
    Sickness Spell
    Pregnancy Spell
    Marriage Spell
    Job Spell
    Protection Spell
    Lottery Spell
    Court Case Spell
    Luck Spell etc. In case you need his help contact him on this email
    address wisdomspiritualtemple@gmail.com he is a good man
    thanks.whatsapp number +234813 648 2342

    ReplyDelete
  29. I can't stop thanking Lord Zakuza for helping me bring back my girlfriend that left me for another man at her workplace.. I was shocked when she broke up with me and I needed help but everything I did to recover her back did not work. If not for the intervention of Lord Zakuza who I met online, I wouldn't have gotten back my girlfriend because Lord Zakuza prepared a love spell that brought her back to me within 48 hours. I love my girlfriend and I'm happy getting her back again. Thank you Lord Zakuza and I promise to share my experience with you to everybody so that anyone that needs help in any way can also get help too for you are a good and wonderful man that God has sent to help those who need help.. Here's his contact information just in case you need any help from him. WhatsApp/call number +1 (740) 573-9483 or Email: Lordzakuza7@gmail.com

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