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that a book with something in it—even a law book— is much more of a book in an elegant dress.

The work of the reporter, Mr. Tobey, has also been done in a very satisfactory manner. Indeed, we know of no reporter who approaches more nearly the ideal reporter. His cases are carefully and intelligently studied; his head-notes are neither excerpts from the opinions, nor undigested statements of the fact, but express clearly and exactly the decision; his statements of the case present the questions distinctlyneither, on the one hand, leaving one to guess at a part of the material facts, nor on the other burying them beneath a mass of verbiage and padding. We are sorry to say that Mr. Tobey has resigned his office. Such reporters are too scarce and too valuable, even as exemplars, to be lost without regret.

There are a number of interesting decisions in the volume, a few only of which we have space to notice. In Spencer v. Hartford, etc., R. R. Co. (p. 14), a railroad company was held liable for building a pier to a bridge obliquely to the course of the river, in such a manner as to cause sand, etc., to be deposited on plaintiff's meadow-land.

In Clark v. Peckham (p. 35), it was held that a riparian owner of land bounded by navigable water has a right of access to such navigable water, of which he cannot be lawfully deprived without the payment of damages; a doctrine contrary to that held in this State and in New Jersey, but which, nevertheless, is reasonable and equitable.

In Remington v. Sheldon (p. 218), plaintiff stored carriages in defendant's barn, and paid the storage; an accumulation of snow broke in the roof of the barn, and injured the carriages. Held, that the defendants were not liable unless they knew, or by the use of ordinary care could have discovered that the building was unsafe.

Pierce v. Proprietors of Swan Point Cemetery (p. 227), was a very curious and interesting case as to property in dead bodies. We gave the greater portion of the opinion in Vol. VI (p. 51) of this journal. One of the defendants had removed the body of her deceased husband from its former place of burial to the cemetery of the other defendant, and the plaintiff, her daughter, sought restoration and an injunction against further interference. The opinion enters quite elaborately into the question of the right of property in dead bodies, and the conclusion reached was that while a dead body is not property in the strict sense of the common law, it is a quasi property, over which the relatives of the deceased have rights which the court will protect, and a demurrer to the complainant's bill was overruled.

In Stafford v. Providence (p. 567), lands were taken by the water commissioners of the defendant for a reservoir. Afterward they decided to take plaintiff's land also. Held, that the plaintiff was entitled to the value of his land at the time it was condemned, although the location of the reservoir had greatly increased its value.

auction a lot of land platted as containing 43,918 feet, at five and one-quarter cents per foot. After conveyance plaintiff ascertained that the lot contained 55,680 feet, and filed his bill for a rescission. The case was a simple one, and the only point, the discrepancy being admitted, was whether the contract was a sale by the foot or as one lot, without regard to quantity.

The plaintiff assuming the former, which the court considered to be proved, asked for a rescission. The answer was not under oath, nor was there any proof of any kind offered by the defendant. The court, instead of deciding according to the pleadings and proofs, neither granted the prayer of the plaintiff nor dismissed his bill; but not only gave the defendant the option to have the land, on making a payment for the excess according to the auction sale, which occurred four years previously, but disregarding the relation of the parties to the suit, directed the plaintiff to convey it to the defendant, provided payment was made within a time to be appointed by the master to whom the execution of the decree was confided. There was an alternative provision in case of the defendant's default, which required the master to compute the amount to be repaid by the defendant to the plaintiff, and he was also to approve a deed to be executed, on such payment, by the defendant to the plaintiff. The master's report, which was subsequently confirmed by the court, by the overruling of the defendant's exceptions, showed the default of the defendant, which rendered nugatory so much of the decree as violated "the course of equity," in making a decree in favor of defendant against plaintiff. It also states the computation of the amount to be paid by plaintiff to defendant, the approval of a deed so long ago as May, 1867, as well as the tender of the money at that time and the proffer of the deed, which had been approved as aforesaid.

It will be seen that not only extraordinary delays occurred before the final report of the master, which was made in October, 1870, but that the court kept the defendant's exceptions before them nearly two years, and while confirming the master's report, by which all the regular proceedings in the case were concluded, they invited subsequent litigation on the part of the defendant, in consequence of which the extraordinary motion was made, to enable him to pay, nearly six years after his default, the money which was to have been paid, in order to enable him to claim, according to the terms of the decree, a conveyance from the plaintiff, the property having been, during the whole intermediate time, in the plaintiff's possession.

The intimation of the court was adopted by the defendant and contrary to the protest of the plaintiff, who contended that the suit was at an end, and that it was utterly impracticable for the court to do any act except to enforce the decree and the proceedings consequent thereon (as for example, to compute the costs, and order the defendant, or, in his absence, the master, to execute formally the deed, which had been proffered to the defendant, approved by the master, on the tender of the money computed to be payable to him), the motion was permitted to be made.

Lawrence v. Staigg (p. 581) was a hotly contested case and gave rise to a very elaborate and learned brief by the plaintiff, the Hon. William Beach Lawrence, on the administration of Equity Jurisprudence. This brief or rather treatise, covered nearly two hundred pages, and was prepared during the" tenth year in court." The case was a bill in equity, filed in 1864, to obtaination, or of counter-testimony, to contradict their

the rescission of a contract of sale on account of mutual error. The plaintiff sold to the defendant at public

The motion was heard; ex parte affidavits were introduced by the defendant. The witnesses, who had been examined before the master, were allowed, without any opportunity to the plaintiff of cross-examin

testimony before the master, and there was no pretense that there was newly-discovered evidence, or any

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evidence which might not have been adduced before the master. The motion was granted, and thereupon, in July, 1873, the plaintiff, Mr. Lawrence, filed his caveat, which, with the arguments therefor, constituted the brief of which we have spoken. The court afterward, without adverting to, and probably without reading the caveat, entered an order, that instead of the 20th of April, 1867, the time before appointed, within which the defendant was to pay for the surplus land, he was given until June 13, 1874.

It seems to us quite apparent, after a somewhat careful study of the opinions of the chief justice and of Mr. Justice Durfee, that the prevailing notion of “Equity” in Rhode Island is, that it is solely depend-❘ ent on one's notion of right and wrong, and that for a judge to administer "Equity," he has only to carry out his individual views. In this case, they not only entertained and granted a motion for further time to execute a decree which had already been executed eight years and the execution confirmed, but they even reversed the relation of the parties, by making a decree for which no process existed, "according to the course of equity," against the plaintiff in favor of the defendant.

A Treatise on the Practice of the Court of Chancery, with an Appendix of Precedents. Second Edition. By Oliver L. Barbour, LL. D. In three volumes. Vol. II. Banks & Brothers. Albany and New York. 1875.

A treatise on "Chancery Practice" seems, at first sight, to be out of place at the present time, since the Court of Chancery has been abolished almost thirty years. But the New York Code, in abrogating the distinction between "law" and "equity," and in giving the courts cognizance of actions, both at law and in equity, did not change the real character of certain classes of legal proceedings. The class of legal proceedings of which the Court of Chancery formerly took cognizance still exists, although the old names are not generally applied to them, and the old forms and old machinery are not used. A work treating of equitable remedies, then, can hardly be said to be out of date or out of place, even in New York State.

Mr. Barbour seems to have found it necessary, however, in order to conform his work to the later order of things in this State, to add numerous and extensive notes to the text of the first edition. In some parts of the present volume, the notes are far more valuable and timely than the text. The work, in fact, may be said to be a double one, the text being the law as administered by the old Court of Chancery, and the notes being the law as administered by the present


The typographical appearance of the present volume is excellent; and this series of practice-volumes, in its enlarged and revised form, will be a valuable acquisition to the literature of equity.

in which railroad corporations have been engaged ever since the period of their organization has produced a mass of adjudication which no other special department can rival. Mr. Lacey has shown commendable zeal and industry in going through all the American cases bearing on railroads and giving in succinct form the results of the adjudications. The subject being a dramatic one, the arrangement of the digest seems to have been necessarily under dramatic heads. Thus we have "Depot Grounds," "Eminent Domain," "Fires,” "Injuries to Domestic Animals," "Injuries to Passengers," etc. By pursuing the plan of abstracting every case in which a railroad company is a party, Mr. Laecy has included many points which cannot be properly classified under railroad law. For instance, under the head of "Costs" we notice several paragraphs like this: "On an appeal from an order, the court may allow the successful party the disbursements for printing the papers and points. Erie R. R. Co. v. Ramsey, 10 Abb. Pr. N. S. (N. Y.) 109, 1870." We think it would be better for Mr. Lacey to have excluded all matter which is not strictly "railroad law" and to have included abstracts of the English cases involving points in this law. The English cases are of great importance, inasmuch as the railroads of England are constructed and operated on precisely the same legal basis as our own. The digest is furnished with a table of cases cited, a table of cases overruled, and a good index. It will be of great service to the profession.



A correspondent writes of a case to which we last week referred:

Although the case of Seamen v. Third Avenue R. R. has been several times referred to and commented on, it has never been reported with sufficient accuracy to show the exact question presented to Judge Larremore for decision on a motion to dismiss the complaint. It appeared by the testimony of the plaintiff himself, that he had paid his fare while in the car, that afterward he stepped upon the front platform, and while there the conductor again demanded bis fare; abusive language was used by both; that plaintiff told him he had paid his fare once, but if he insisted on it that he would pay it again; that he put his hand in his pocket for the money to do so, but the conductor refused to take the fare, and proceeded to push him from the platform; that he told the conductor if he would stop the car he would get off, but that the conductor refused to do this, and in a personal altercation which ensued, the conductor violently shoved the plaintiff from the platform; that in falling he caught the railing with one hand, his hold of which was broken by the conductor

A Digest of Railway Decisions. By John F. Lacey, of the Iowa kicking his hand, and as a consequence he fell, and was Bar. Chicago: Callaghan & Co., 1875.

This digest includes all the reported American cases, in which a railway company is a party, and all other cases in which questions are passed upon involving railway law. The original design of the work, we are told, was simply a "Digest of American Railway Law, but it was found, upon examination, that without very much enlarging its size, it could be made to embrace the principal points of every railway case."

The demand for a good digest of railroad law is quite apparent. The immense amount of litigation

injured. It will be seen that the plaintiff's own statement brought the case directly within the ruling in Isaacs v. Third Ave. R. R., 47 N. Y. 122, the plaintiff's counsel not being able to point out any satisfactory distinction between the cases. It is only just to the defendants to say, that while invoking the principle of law applicable to the facts presented by the plaintiff's case, they were prepared to defend the suit on the merits on grounds not only relieving them from legal responsibility, but the conductor from all blame or misconduct.


THE following decisions were handed down in the New York Court of Appeals on Tuesday, April 27, 1875:

Motion denied without costs-Hoppough v. Struble.—Judgment affirmed with costs - Booth v. Spuyten Duyvil Rolling Mill Co.; Jeed v. Morton; Moores v. Lunt; Gates v. Beecher; Adams v. Mills; Osborn v. Gantz; Brundage v. Brundage; Dalrymple v. Hillenbrand; Burhans v. Hubbard; Jones v. Hummil.Judgment reversed and new trial granted, costs to abide event -Schaley v. Mumford; Bell v. Dagg.Appeal dismissed with costs-Williams v. Montgomery; In re opening and widening Hudson avenue.Order affirmed with costs - People ex rel. Little v. Willsea; People ex. rel. Mann v. Mott; Elwanger v. Fish; White v. Livingston. Order granting new trial reversed, and judgment of Special Term affirmed with costs - Blanchard v. Western Union Telegraph Co. Judgment of General Term affirmed, with costs Higgins v. Deleware, etc., Railroad Company. Order affirmed, and judgment absolute for plaintiff on stipulation with costs ·Cole v. Mann.


COURT OF APPEALS ORDER. Ordered, That the clerk make a new calendar for the 24th day of May next, to which day this court will take a recess by adjournment from the 30th instant, and that he place on such calendar all causes on the present calendar which shall not have been heard or otherwise disposed of; also, such pending appeals as shall be regularly noticed for argument and in which notes of issue and proof of notice of argument shall be filled with the clerk on or before the 10th day of May. E. O. PERRIN,


Clerk of Court of Appeals.


E have received the General Syllabus of Law Studies, prepared and arranged by Professor Edmund H. Bennett, LL. D., for the students in the law school of the Boston University. There are twelve general heads, viz.: 1. Introduction and general Principles. 2. Of Personal or Bodily Rights. 3. Of Rights to Property, Personal and Real. 4. Of Rights arising from Personal Relations. 5. Of the Lex Mercatina or Commercial Law. 6. Of Maritime and Amiralty Law. 7. Of the Law of Equity. 8. Of Private Wrongs or Civil Injuries, and Modes of Redress. 9. Of Public Wrongs or Crimes, and Modes of Prosecution. 10. Of Political and Constitutional Law. 11. Of International Law; and 12. Of Pleading and Evidence. Dr. Bennett gives a list of text-books to be read under each head, and makes the excellent suggestion that the student shall always read with a law dictionary open before him- Professor Simeon E. Baldwin, of the Yale College law school, has prepared a pamphlet containing the constitution of the United States, with references to judicial decisions. It is designed principally for the use of the students of the law school. The notes and references are quite valuable though not extensive.

Mr. Samuel D. Sewards, LL.D., of New York, has issued a pamphlet on the "Registration of Written Instruments Affecting Title to Real Estate, with a brief historical review of the subject; also a statement of the defects of the present system and suggestions

as to its improvement." The author refers to the facility of committing mistakes, on the part of the clerks, in making up indices of deeds, and states that the courts have decided that the false index is no defense to the party deceived. But the great defect in the present system of registration is, that the fast accumulation of record books will, at length, render all research futile, if not impossible. For these and other defects, Dr. Sewards suggests that short forms of deeds be adopted, such as we referred to last week. His next suggestion is, that "deeds be not literally copied into books of record, but that the originals be kept on file, and certified copies thereof, with the certificate of record, returned to the party, and reference had to their principal parts * * * in a book, which would be the only book of entry, both for conveyances and mortgages, and all other incumbrances, and so arranged that every parcel of land have its separate folio, containing the description of the property and the name of the owner, who, on the principle of mercantile bookkeeping, would be credited with the title he possesses, and charged with the mortgages and other incumbrances thereon." In order to obviate referring to the past record, and thus save a great amount of time in making abstracts of title, Dr. Sewards thinks that the "legislature should appoint a commission with power to examine upon applications, and certify to the titles of the present owners of real estate, and enact a statute, in the nature of the statute of limitations, declaring the new record final, when made upon the certificate of such commission, and after proper publication, if not objected to within a certain time." Other changes are also suggested.

A suit has been brought by the Goodyear Dental Vulcanite Company to recover royalty for the use of vulcanized rubber, amounting to upwards of $7,000,000. It is a test case, and Dr. George Willis is the nominal defendant, although the suit is practically defended by all the dentists in the United States, some 15,000 in number, under the auspices of the Dental Protective Union of Michigan, of which Dr. B. T. Spellman is president. The Nashville Commercial and Legal Reporter thinks the state of society in Tennessee demands a more frequent resort to actions for breach of promise of marriage. It also advocates making it an offense punishable by imprisonment, for a man to break his promise to marry. It makes the alarming assertion that "the penitentiary of the State is the proper asylum for a majority of these matrimonial bankrupts, and it may not be going too far to say that the gallows would be a wholesome resting-place for many of them."-Chief Justice Benjamin F. Graves has been re-elected to the Supreme Court of Michigan without opposition, being nominated by both parties. Senator Christiancy's successor on the bench is Isaac Marston, lately attorney-general of the State. Mr. Marston is of Irish birth, and is about thirty-five years old. He graduated in the class of 1861, at the law department of the University of Michigan.

In one of the trial terms of the Marine Court of New York, a case was tried between two Italian female organ-grinders, which, though otherwise of no public importance, disclosed the fact that organ-grinders are not always subjects deserving of pecuniary sympathy. In this case it appeared from the testimony that the parties to the suit had had cash loans pass between them amounting to nearly $300 at a time.

"G. W. S.," the London correspondent of the New York Tribune, says: "The hero of the hour is Mr. Serjeant Ballantine. His successful-for it is practically successful-defense of the Guikwar of Baroda has more than restored whatever prestige he may have lost from his connection with the losing side in the Tichborne cause. In India he is looked upon by the natives as a man who has overthrown the English Government in a conflict where the whole power of the Government was brought to bear against a native Prince. In England it is of course only his professional renown which is enhanced, but the circumstances are so peculiar that they will be long remembered. He went to India at a moment's notice, tempted by a fee which, large as it is, would scarcely have been large enough to secure his services five years ago. He was to have $50,000 for a journey of three months. It was said at the time that an effort was first made to retain Mr. Hawkins. That eminent barrister declined, because no fee could compensate him for the loss of practice which would follow so long an absence. Serjeant Ballantine is reported to have lost a portion of his from the mere length of time during which he was occupied in the Tichborne business. English habits are peculiar. When attorneys and clients find they cannot get the man they prefer in a particular cause they must necessarily go to some one else. The mischief is they are likely to keep to the second man, and the first gradually drops out of the custom which has so long been his. This ought to have been true, it would seem, in Mr. Hawkins' case as well as in Mr. Ballantine's. I suppose Mr. Hawkins' wonderful success brought back his old clients. Be that as it may, there is no doubt that his great rival has regained all his old fame, and more than all. The leading journal of England paid him the extraordinary compliment of saying that the result of the trial would probably have been different but for his cross-examination of Col. Phayre-the whole of which it reprinted. The American public has been taking a good deal of interest lately in the art of cross-examination. You would perhaps find Mr. Serjeant Ballantine's performance not less masterly than those of Mr. Evarts and Mr. Fullerton. I have read my share of all three, and I am not clear which ought to be called the most subtle, the most persuasive, or the most deadly."

The Monthly Western Jurist for April, contains articles on "Garnishment" and "Amendments in Election Cases;" also, several cases reported at length with notes. This number completes the first volume of the Monthly Western Jurist.· -The grand jury at Leeds, England, recently made the following presentment to Baron Amphlett: "The grand jury in concluding their duties, and bearing in mind the observations of his lordship upon the increase of crimes of violence, beg permission respectfully to invite the judges' attention to the fact that in nearly all the cases that have come before them where violence has been committed, whether in aggravated assaults, or in the brutal beating of wives, or in the form of licentious outrages upon women, the exciting cause has been strong drink, and the criminals are shown to have often issued from the public house or beer-house in such a state as to have lost reason and self-control. Without offering any opinion on the efficacy of the different kinds of punishment, the grand jury believe that no degree of severity is sufficient to deter the drunkard whose blood is inflamed and whose mind is blinded and

maddened by drink from acts of violence and outrage; and it is, therefore, in the interests of both the victims and the perpetrators of these crimes in short, of the whole public that attention should be drawn as well to the exciting cause as to the severer punishment of each offense."

The expenditure in respect of the new courts of justice in London up to the end of the year 1874, reached £1,042,905. As much as £933,288 of that sum had been spent in the purchase of the site and in incidental charges, and £85,596 in payments on account of contracts for the foundations and erection of the courts and offices, and architect's commission. The civil service estimates show that a further vote of £75,000 is now proposed for the erection of the building; the revised estimate for this is stated at £826,000. — The Australian Jurist says that a lady in the country, having to make an affidavit, and being too ill to come to Melbourne, sent the following letter to her solicitor: "Sir-I am so ill I am not able to attend, but I'll swear to all you say as being true. I have kissed this book (Bible) twice, which I send by bearer. I am," etc. We should be sorry to spoil this simple unvarnished tale by any comments of ours. Its naïve simplicity speaks for itself. It is stated that there is a vacancy in the University of Calcutta of a Tagore law professorship, the salary attached to which is 10,000 rupees per annum. The professor will be required to deliver in each year a course of lectures on some branch of Hindoo, Mahomedan, or Anglo-Indian law. is stated that the title of Serjeant Ballantine, the defender of the Guicowar of Baroda, has occasioned no little perplexity to his admirers in India. The native newspapers have been making many attempts to render the designation "Serjeant" intelligible to their readers; but a Punjab journal of superior acuteness has at length solved the difficulty by suggesting that the proper way of writing the name is "Sir Joint Ballantine."


A new professorship entitled "The Story Professorship of Law," has been established at the Cambridge Law School. -Judge Mackey, of South Carolina, has just ruled that "in the trial of an issue of fact, involving the examination of a written or printed instrument, it is good ground of challenge to a juror that he cannot read." The ruling will have an important bearing on the composition of juries, and consequently on the administration of justice in that State. A libel suit brought by Mr. Willis Phelps against the Springfield (Mass.) Republican, to be tried very soon, excites much interest in Massachusetts. $200,000 damages are asked because of the comments of the Republican upon the connection of Mr. Phelps and members of his family with railroad grants which were much talked of in western Massachusetts a year aud a half ago. The question of these grants entered into local politics, in which Mr. Phelps and his sons, who were interested as railroad contractors, took a prominent part, which the Republican denounced unsparingly. The Republican meets the charges squarely, saying that it "recognizes the fact that it is on trial in the most vital of its ambitions, the most sacred of its duties, the dearest of its reputations, and will contest the issues of the trial accordingly." Henry Morris, of Springfield, and Judge Thomas, of Boston, are the leading counsel for the plaintiff, and N. A. Leonard, of Springfield, and Richard H. Dana, Jr., of Boston, for the defendant.

All communications intended for publication in the LAW JOURNAL should be addressed to the editor, and the name of the writer should be given, though not necessarily for publication.

Communications on business matters should be addressed to the publishers.

The Albany

Albany Law Journal.

ALBANY, MAY 8, 1875.


THE United States Government Printing Office has issued a volume on the "Laws of Claims against Governments, including the modes of adjusting them, and the procedure adopted in their investigation." It was originally prepared by Mr. Lawrence, a member of the last House of Representatives, and submitted as a report from the Committee on War Claims in February. The object is to show that the custom of examining claims by committees of congress should be entirely abandoned, and appropriate tribunals created for the purpose having judicial powers, and aided by the machinery now operated by the Commissioners of Claims. The opinions of the tribunal on questions of law should be subject to review by the Supreme Court. The report condemns the practice which has grown up of officers in the department, and even the courts, rejecting claims on the ground that no law authorizes the payment, and at the same time suggesting that a remedy may be sought in congress. It is asserted to be no part of the duty of these officers or the courts to advise claimants as to means of relief, in opposition to the established law, nor to make recommendations to congress; and that congress can with no more propriety disregard law settled on correct principles than courts or officers in the departments. Another matter to be observed is, that unauthorized suggestions to congress for relief often involve claimants in and disapexpense pointment.

The withdrawal of the Judicature Amendment Bill, in the British House of Lords, has been followed by the introduction of another bill, by the Lord Chancellor, the design of which is to suspend, for a year, the operation of the two clauses of the act of 1873, taking away the appellate jurisdiction of the House of Lords in the case of English appeals. No repeal or alteration of the provisions of the act of 1873, relating to appellate jurisdiction, is proposed, but a simple suspension of the operation of the act is asked for with a view, doubtless, to procuring a change in the attitude of the House of Lords in reference to the whole subject of appellate jurisdiction, before the next session. The new bill also recommends an intermediate court of appeal consisting of five ex officio members the Lord ChanVOL. 11.- No. 19.


cellor, the Lord Chief Justice, the Master of the Rolls, the Chief Justice of the Common Pleas, and the Chief Baron of the Exchequer. In addition to these ex-officio judges of the intermediate court of appeal, there are proposed five ordinary judgesthe two Lord Justices of the Court of Appeal in Chancery, two salaried members of the judicial committee of the Privy Council, and one other judge to be appointed in a manner indicated by the act. Three judges are to constitute a quorum in the case of "final" decrees or judgments, and two judges in the case of interlocutory decrees or judgments. Some of the lords protested against the delay in settling the question of final appellate jurisdiction; but it is not likely that this matter will be decided during the present session.

The Pall Mall Gazette thinks that the ultimate result of the postponement of the decision on the question of final appellate jurisdiction will be the repeal of the suspended sections of the act of 1873, and the re-instatement of the House of Lords in the position of Supreme Court of Appeal for the whole United Kingdom. The Lord Chancellor, in introducing the new bill, said that there must be only one court of final appeal for the three kingdoms, and if he and his followers cannot effect a change in the position of the House of Lords before the next session of Parliament the result predicted by the Pall Mall Gazette must follow. Outside of the House of Lords the prevailing opinion seems to be that a change ought to be effected in the final appellate jurisdiction; and that the highest legislative and highest judicial functions should be exercised by separate bodies. We presume that this view will prevail in


The Supreme Court of the United States has adjourned until the first Monday in October next. There are several very important cases which were argued at the last term of this court, but which are held under advisement until the next session. Among these is the celebrated case of The United States v. Cruikshank, which was argued with consummate learning and ability by David Dudley Field and Reverdy Johnson, and which involves the constitutionality of the Enforcement Act. The New York Court of Appeals is taking a short vacation, leaving the case of Tweed undecided. This court will convene again on the 24th of May.

At a meeting of the International Code Committee in New York, recently, arrangements were made for the conference of the Association for the Reform and Codification of the Law of Nations, to be held at The Hague the first week in September next. A considerable number of prominent publicists and jurists were present and delegates were appointed to attend the September conference. Mr. David

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