Each state has its own statutory grounds for divorce. (attorneys.com)
Because the Court decided this question on statutory grounds of insufficiency of evidence, it did not need to reach the more sweeping constitutional questions that seem fairly implicated here. (scotxblog.com)
The FTCA is the «exclusive means by which a party may sue the United States for money damages... in tort» pursuant to 28 USC § 2679, but this is really something of an exaggeration as there are lots of constitutional and statutory grounds upon which the United States government can also be sued for money damages that naively appear tort - like, such as a reverse condemnation action under the 5th Amendment to the United States Constitution. (law.stackexchange.com)