Where there are no limitations on adoption of statutes by reference, the checking of abuses must rest on the rules of the legislatures and the integrity of the members alone, for the accepted doctrine is that the legislature has power to adopt any statute except as prohibited by the constitution. A striking example of what may not be done under these provisions is shown in a recent Pennsylvania case.2 A merchant had sold in less than the original package certain "evaporated peaches" treated with sulphur dioxide, a substance harmful to health. A state law of 1895 had forbidden the sale of any food treated with substances injurious to health. In 1906 Congress had passed a pure food act regulating the subject so far as it was within the field of national legislation. The use of a certain amount of sulphur dioxide was permitted. In 1907 the former state act was repealed and a new one put in its place which continued most of the former provisions but declared no actions should be sustained when the foodstuffs were "not adulterated within the meaning of the provisions of the 'Food and Drugs Act' of June 30, 1906, enacted by the Senate and House of Representatives of the United States . . . and the rules and regulations promulgated from time to time for the enforcement of the same." The peaches, in the case before the court, were not adulterated to an extent sufficient to bring them within the prohibition of the Federal act. The question raised by the state was, could the state legislature adopt the provisions of a Federal act, as was attempted in the law, in spite of the state constitutional provision against extending laws 1 Atty. Gen. v. State Board of Assessors, 106 N. W. 698 (Mich. 1906). 2 Commonwealth v. Dougherty, 39 Pa. Superior Court 338 (1909). by reference. The court held this could not be done. "Our legislature could not introduce into a statute an act of Congress by a mere reference to its title. Much less could it inject bodily into the same statute all of the rules and regulations that might be from time to time promulgated." 1 CHAPTER IV TITLES OF BILLS As the complexity of legislation has increased it has become essential to introduce many formal requirements which were unnecessary or unimportant when the work of the elective chambers was chiefly the granting of supplies. Regulation of public powers and the relations of man to man are difficult problems and demand new machinery for their solution. Some of the changes introduced refer to parliamentary procedure only, others to the form in which the subjectmatter of the law must be arranged. In both cases the practice of American legislatures has been adopted from the mother country, England. Custom had developed the use of certain forms for bills in Parliament long before the settlement of America, though the failure to observe the requirements or the inaccuracy of the drafting of bills was never enough to upset validity. Even today this is the case. When the sovereign power speaks it is unnecessary to inquire whether the command is given in the customary way, and failure so to do can never bring the bill into court. American practice has developed far from this standard. In no case is the contrast stronger than in the rules in England and America relating to the titles of bills. Custom and law in England have made bills there conform to the same standard striven for in America in fact the English practice of employing a special parliamentary officer to have charge of the form of all bills has given an effective guarantee that the |