257; Reynolds v. United States, 98 U. S. 145 and Strander v. West Virginia, 100 U. S. 303, are interesting examples of his methods of reasoning. At the time of his resignation “his eye was not dim, neither was his natural force abated," and nothing but the sincerest regret can attend his own voluntary act by which, in the midst of a most important and influential career, he became judice mortuus. HAMPTON L. CARSON. Prof. Huifcut's of the Law Owing to the ever increasing importance of the subject of legal education, and particularly to the recent discussion as to the merits of the various systems of teaching, the address of Prof. E. W. Huffcut, of the Cornell University School of Law, upon "The Relation of the Law School to the University" will be read with much interest by all members of the profession not fortunate enough to hear it delivered. The following brief resumé of the address, prepared by the author's courtesy for publication here, will convey a general idea of the conclusion at which Prof. Huffcut arrives : School to the There were seventy-three law schools open during the past year in the United States for the reception of students. Of these all but seven are connected with the colleges or universities. Nearly nine thousand students were enrolled in these schools, of whom but twenty per cent. were college graduates. In fifty university law schools the average of college graduates was but ten per cent. In these same schools there are practically no requirements for admission, and when there are any require ments they fall considerably below the requirements for admission to the Freshman class of the college. The university law schools owe it to themselves and to the profession to lift these standards of legal education. Until very recently there has been no relation whatever, save a nominal one, between the law school and the university. While the standards for admission and graduation in the Universities have steadily advanced, the law schools have made 'Delivered before the American Bar Association at its Annual Meeting in Detroit, August, 1895. little improvement in requirements for admission or in the matter of conforming to university standards of education. Some advance, however, has been made, though curiously enough it indicates a wide difference of opinion as to the nature of the relation of the law school to the university. Thus far the attempts to create a real relation between the two have taken three quite distinct directions, which, for convenience, may be termed the Harvard plan, the Stanford plan and the Cornell plan. The Harvard plan is to treat the law school as practically a graduate department of the university. Beginning with the academic year, 1896-97, only those having a baccalaureate degree in arts, literature, philosophy or science from some approved university or college, or those qualified to enter the senior class of Harvard College, will be admitted to the school as candidates for a degree. This insures an adequate preliminary education and is a long step toward raising the standards of legal education. It is obvious, however, that very few schools can venture to follow this leadership for the present. It would be unwise to adopt everywhere a standard which would drive the bulk of the students back into the offices for their legal training. The Stanford plan is to treat the school as practically an undergraduate department of the university. Students in that university elect any one department for the major part of their work, and, for the purposes of this election, law is placed upon precisely the same basis as any other department. It follows that the requirements for admission are the same for all students whether their major work is law or literature or any branch of the humanities or of science. Those electing law are graduated with the degree of Bachelor of Arts in Law. A post-graduate law course is projected, open, like other postgraduate departments, to graduates who have spccialized during the undergraduate course in the corresponding subject. This plan seems an admirable one, but it can be adopted only in universites having a curriculum similar to that of Stanford. The Cornell plan is to treat the school as an independent organization within the university, but to relate the school to other departments by permitting juniors and seniors in the University to elect subjects in the law school equivalent to one year of law work, and count the same toward the baccalaureate degree in arts, philosophy or science. If the remaining work of the school is taken after graduation the degree in law is then conferred. By this plan the student shortens the combined work of the college and law courses by one year. The law students who do not come to the school through the university are permitted to elect studies in the college, particularly in history and political science. Some students of this class take a year longer for their law course than is required, and enlarge the course of study by elections in other departments. This plan is followed already in several universities, and it seems with entire satisfaction. Of the three plans of relating the law school to the university, the third seems, under all the existing conditions, the most practicable. It needs, however, to insure higher qualifications, one additional feature. At present a student may enter the school with a preliminary education lower than that required for admission to the college, and take only the required law work. The door is still open for those who are inadequately prepared. To meet this defect there are two possible remedies. The first is to raise the entrance requirements to about what would be required to enter the the junior class of the college. The second is to require those students who do not come to the schools through the university to take a ycar longer for their course than those who do, and to occupy the additional time thus required in studies selected from the college. Each of these alternatives has much to commend it, and perhaps there is little to choose between them. Either would certainly raise the standards of legal education. The University Law Schools ought to face these problems and solve them. The cause of legal education, and therewith the most vital interests of society, is in their hands. The law office is fast losing its function as a training school. The schools are more and more to educate the members of the profession. They ought to educate them in the true university spirit, broadly and deeply, not as makers of craftsmen but as promoters of legal scholarship. THE AMERICAN LAW REGISTER AND REVIEW. NOVEMBER, 1895. PROGRESS OF THE LAW. AS MARKED BY DECISIONS SELECTED FROM THE ADVANCE REPORTS FOR OCTOBER. Edited by ARdemus StewART. We print this month the opinion of Judge RITCHIE, of the Superior Court of Baltimore, referred to last month, in which he holds that the purchaser of a section in a Pullman sleeping car for a given trip has the right, on leaving the train before he reaches his destinaTransfer of tion, to transfer the use of his section to another first-class passenger, for the rest of the trip for Carriers, Passengers, Pullman Sleeper, Ticket which it was sold. 'This suit is brought to recover damages for having been ejected from a certain section in one of the defendant's sleeping cars. So far as it is necessary for me to refer to the facts in the case, they are as follows: On the 30th of September, 1893, Mr. Curlander and his wife, the plaintiffs, left Baltimore upon the Baltimore and Ohio Railroad for Chicago; on the same day some gentleman and his wife, whose names are not known, but whom I will designate as Mr. and Mrs. "X.," boarded the same train at Washington for the same city. All parties were entitled to a first--lass passage to Chicago. "Mr. X. had bought and paid for the use of section number one on the Pullman Sleeper, "Valley Falls," attached to said train, from Washington to Chicago, and held a ticket for the same. The only restriction printed upon this ticket was "Good for this date and car only when accompanied by a first-class railroad ticket." During the day the Pullman con ductor took up this ticket and gave Mr. X. in lieu thereof a check for the use of the section in question. This check showed on its face the same trip, that is, from Washington to Chicago, and the only limitation on it touching its use was: 'This check is good for this trip only.' On the evening of the same day, at Pittsburg, Mr. Curlander bought for himself and wife the upper berth of section six in the same car and paid for its use from that point to Chicago. On the next morning, after the car had been arranged for day travel, it was found that the seats which went with the upper berth were those which faced the rear of the car and required the plaintiffs to ride backwards. After riding a short time in this position Mrs. Curlander had a severe attack of nausea; observing her sickness Mrs. X. invited her to a seat in her section, where she rode facing the engine, and was much relieved by her change of position. Mrs. X. then told her that she and her husband would soon leave the car, having determined to get off at Deshler, a station about seven hours distant from Chicago, and said that her husband would give their section to Mr. Curlander so that she would not have to ride backwards. On leaving the train at Deshler, Mr. X. accordingly told Mr. Curlander that he might have his section for the rest of the trip; and transferred to him the check which he held for the same. A little further on, at Defiance, the Pullman conductor, knowing that Mr. and Mrs. X. had left the train, sold the section over again from that point to Chicago to parties who boarded the train at that station. Upon bringing these persons to the section he found it occupied by the plaintiffs. Being requested to vacate and return to their former seats, Mr. Curlander told the conductor that the section had been given to him by Mr. X., and showed him the check which he held therefor, offering to the conductor at the same time the use of his two seats in section six. An altercation ensued, the conductor of the train was called in, and while there is some conflict as to whether the ejection was the act of the defendant or of the train conductor, the plaintiffs were compelled to vacate the section. Soon after returning to her former seat, Mrs. Curlander again suffered from severe nausea |