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acquire a domicile American conflict American courts American law basis of jurisdiction Beale capacity to marry choice of law common law concept of domicile concerned conflict of laws conflicts rules contract Court of Appeal decision divorce jurisdiction domicile of choice domicile of origin domiciled in England domiciliary law England England and America English and American English conflict English courts English law essential validity exist fact factors faith and credit Federal full faith governed Graveson Griswold and Reese House of Lords interest Joseph Story judicial jurisdiction in divorce law of England laws rules legal systems lex loci celebrationis locus regit actum Matrimonial Causes Act matters Nevada Nevada decree parties place of celebration principle of locus Private International Law Privy Council problem proceedings proper law recognition recognized residence rule of locus rules of conflict separate domicile social status of marriage Supreme Court tort United Kingdom United States Supreme validity of marriage