It would not be fitting to say in the language of the stage that Williams v. North Carolina has drawn the curtain on Haddock v. Haddock. Rather we will shift the metaphor to say that the recent case from North Carolina has largely stripped the flesh from the earlier decision. Yet the bones of Haddock v. Haddock remain unbleached and unpulverized. Just as persons with mechanical turn of mind may frame from blocks of wood puzzles of readjustment and resetting, so courts in states that do not favor free and easy termination of marriage may still find in the osseous remains of the Haddock case material to fashion some puzzles for the Supreme Court of the United States to solve-puzzles upon which law students and their teachers in the meantime may speculate.
Harold W. Holt,
THE BONES OF HADDOCK v. HADDOCK,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol41/iss6/2