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The manifold impact of Communism on our society has created variant problems for the judiciary. It is, therefore, not surprising that the issue of "communism as grounds for divorce" has been raised occasionally in divorce litigation. The recent case of Donaldson v. Donaldson1 dealt directly with this question. This was an action by the wife against the husband for a divorce. The defendant answered with a cross complaint requesting that he be awarded the divorce and custody of a minor child. The plaintiff's complaint was dismissed and the counter claim allowed. The Supreme Court held that the fact the wife was a member of the communist party at the time of her marriage and refused to continue in the religious beliefs of her birth did not entitle the husband to a divorce. The decree was reversed and remanded. The court said:

Political and Religious Differences as Grounds for Divorce ... with the Accent on Communism