In Bradwell v. State, 16 Wall. 130 (1873), three Members of the Supreme Court reaffirmed the common-law principle that "a woman had no legal existence separate from her husband, who was regarded as her head and representative in the social state; and, notwithstanding some recent modifications of this civil status, many of the special rules of law flowing from and dependent upon this cardinal principle still exist in full force in most States." Id., at 141 (Bradley, J., joined by Swayne and Field, JJ., concurring in judgment).