This constraint arose out of the desire to ensure that all of the bases for divorce be adequate. Prior to this, people used such issues as incompatibility or a decline in as grounds; the court eventually came to see these problems as not severe enough to warrant divorce, however. In the 1970s, no-fault grounds gained favor in many states, and in 2010, New York became one of the last of the fifty states to allow no-fault divorces even in cases where there was no mutual consent to the divorce. The other states still requiring mutual consent for no-fault divorce are Tennessee (except where there are no minor children and the couple have lived apart for two years), Mississippi, and South Dakota.