Greater scholarly efforts have been expended by writers in continental Europe than in the English-speaking countries in tracing the development of theories of the conflict of laws. Even among the continental authorities, however, this writer has not found any substantial piece of scholarship addressed specifically to the development of the conflicts rules relating to marriage. The history of marriage conflicts rules deserves treatment apart from the history of conflicts rules generally, because essential marriage law and essential marriage conflicts law were for a long while exclusively the province of the Church, and not addressed by secular jurists.