Originally the rule was that the domicile of a married woman was that of her husband. It made no difference what the actual facts were, a wife would not be heard to say that she had a separate domicile. This notion was largely due to the law's conception of a married couple as one person, which idea was based on a wife's duty to be with her husband, he in turn being bound to support her.
James L. Parks,
Domicile of a Married Woman, The,
29 Bulletin Law Series.
Available at: https://scholarship.law.missouri.edu/ls/vol29/iss1/4