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statute provides for constructive service of process by publication, as a substitute for personal service, it must be strictly followed in order to bring the party served within the jurisdiction of the court. Where a statute required that a defendant served by publication should be given three months in which to appear and plead, and an order made and published in a case gave defendant only two months, held, that a judg ment entered therein was a nullity. Gray v. Larrimore, 2 Abb. C. C. 542; Settlemeir v. Sullivan, 97 U. S. 444; Brownfield v. Dyer, 7 Bush (Ky.), 505. Morey v. Morey. Opinion by Cornell, J.

MUNICIPAL CORPORATION-CANNOT BE GUILTY OF CONTEMPT. — A municipal corporation cannot be guilty of a contempt in disobeying an injunction; such contempt, if any, in disobeying a writ directed to the city must be the contempt of individual persons; as, for instance, of officers of the city. Davis v. Mayor, etc., of New York, 1 Duer, 484, 509-10; London v. Lynn, 1 H. Bl. 206. Bass v. Cily of Shakopee. Opinion by Berry, J.

PENNSYLVANIA SUPREME COURT ABSTRACT.

MAY, 1880.

CONSIDERATION-MORAL OBLIGATION OF MARRIED WOMAN. The debt of a married woman, which she is not bound to pay, will prove a sufficient consideration to support an obligation under seal, by a third person, to pay it. It is true, as a general rule, the contract of a married woman is void, so that no action will lie against her for its breach. To this, however, there are some exceptions. Although no recovery may be had against her, it by no means follows that the equity of the claim may not be sufficient consideration to support the express promise of a third person to pay it. It has been held to be a sufficient consideration to support the promise of the wife herself, made after her coverture had ceased, and she had become sui juris. Brown v. Bennett, 25 P. F. Smith, 420; Trout v. McDonald, 2 Norris, 144. The tendency of the authorities is to treat the disabilities of a married woman as a personal privilege, which does not extend to any person who unites with her in a contract. Thus, if she execute a note jointly with her husband she may not be bound, yet he shall be bound for the whole. Unangst v. Fitler, 3 Norris, 135. Leonard v. Duffin. Opinion by Mercur, J.

HUSBAND AND WIFE-CONTRACT BY WIFE BEFORE MARRIAGE.-. -A woman hired a dwelling-house and took possession, agreeing to pay a specified rent. Thereafter she married, continued to occupy the house, her husband not living with her but visiting her frequently, and occasionally remaining with her over night. Held, that the husband was not liable for the rent of the house accruing after the marriage. The duty of a man to support and maintain his wife is well settled, and may be enforced by legal process in case of his refusal or neglect to do so. But he was a stranger to this contract. The lessee was in possession of the premises under a lease when he married her. contract and liability were hers. He no more assumed the payment of her liability under the lease than he did of her other debts, if any existed. It is true she lived in and enjoyed the use of the house for some months after her marriage. In like manner her clothing purchased before was worn and used after marriage if unpaid for, the husband could not be held responsible for it. Biery v. Ziegler. Opinion by Paxson, J.

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The

NEW YORK STATE BAR ASSOCIATION.

ORDER OF BUSINESS OF THE FOURTH ANNUAL MEET-
ING OF THE N. Y. STATE BAR ASSOCIATION, TO BE
HELD AT THE SENATE CHAMBER, IN THE
NEW CAPITOL IN THE CITY OF ALBANY,
TUESDAY, NOVEMBER 16, 1880.

Morning Session.

The meeting, which will be held in the Senate Chamber in the New Capitol, will be called to order by the Hon. Samuel Hand, President, at 10 o'clock in the forenoon. The morning session will be devoted to the transaction of business in the following order: 1. Appointment of committee to nominate officers for the ensuing year.

2. Reading minutes of last meeting. 3. Nominations for membership.

4. Report of Executive Committee. Mr. Albert Mathews, Chairman.

5. Report of the Treasurer. Mr. Martin W. Cooke. 6. Report of Committee on Admissions. Mr. Peter S. Danforth, Chairman.

7. Report of Committee on Law Reform. Mr. Matthew Hale, Chairman.

8. Report of Committee on Grievances. Mr. John F. Seymour, Chairman.

9. Report of Committee on Legal Biography.

John F. Baker, Chairman.

10. Election of Members.

11. Election of Officers.

12. Reports of Special Committees.
13. Miscellaneous Business.
14. Special Orders.

Afternoon Session.

Mr.

The Association will reconvene at 3 o'clock P. M., when the following will be the order:

Aunual Address, by Hon. George W. Biddle, of Philadelphia, Penn. Subject: "Retrospective Legislation."

Report of the Committee on Prizes. Mr. John I. Gilbert, Chairman.

Essays will be read by members of the Association, as follows: Hon. Matthew Hale, of Albany; Edward E. Sprague, of Flushing; James D. Teller, of Auburn; Joshua Gaskill, of Lockport, and others, upon subjects to be announced.

All members of the Bar are invited to attend the afternoon session.

At 6.30 o'clock P. M. the annual dinner will be had at the Kenmore Hotel.

Tickets may be procured at the Kenmore Hotel, and from the members of the Committee. By order of the Committee of Arrangements. TOMPKINS WESTERVELT,

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Chancery, 2, 3 Gill & Johnson, 9, 10 Pickering, 5 New Hampshire, 6 Halstead, 2, 3 Wendell; and important notes on nuncupative wills; whether jury bound by erroneous instructions; nature and scope of bills of review; action of land officers, when conclusive; custody of child on habeas corpus; mandatory injunction, jurisdiction to grant; insurable interest; contribution between joint principals, one being insolvent; validity of mortgage for future advances; action for possession of chattels levied on under execution.

LANDRETH ON SALE.

A Brief Analysis of Sale. An Essay. By Lucius S. Landreth, of the Philadelphia Bar. Philadelphia: Rees, Welsh & Co., 1880. Pp. x, 65.

This monograph combats the almost universal idea that on a contract of sale of goods, where nothing remains to be done by the vendor, as between him and the vendee, the property vests in the vendee, the vendor retaining only a right of possession until payment. The author advocates his theory ingeniously, and fortifies it by some eminent authorities, but the contrary rule is so firmly fixed that nothing short of legislation can modify it. And for ourselves, we see "no need of a change."

SAXTON'S TAX LAWS, AND EXCISE LAW, ETC., of NEW YORK.

Laws of the State of New York relating to the Assessment and Collection of Taxes, including the Statutes of 1880. Containing the Laws relating to Treasurers, Supervisors, Assessors, Collectors, and all officers under the General Tax Laws. With Notes of Judicial Decisions and an Appendix of Forms. By William W. Saxton. New York: S. A. Wilder & Co., 1880. Pp. 269.

Ercise Law of the State of New York, with Civil Damage Act, and all Statutes, including 1880. With Notes of Decisions of the Courts and Forms. By William W. Saxton. Second Edition. New York: S. A. Wilder & Co., 1880. Pp. 76.

These are convenient manuals, but the former will hardly supersede Mr. Thompson's Supervisor's Manual and Assessor's, Collector's and Town Clerk's Manual. Neither of the present works professes to be in any sense a treatise, and the references to decisions are the barest. The latter manual we should judge likely to be the more useful, and quite useful, although under the civil damage act the references to decisions ought to be much more ample. Mr. Lawson's manual on this subject is a model. In one point of view, however, these manuals have a superiority- they propose to come down to the present year in statutory citations and adjudications.

OBITUARY.

LORD JUSTICE THESIGER.

THE Right Hon. Alfred Henry Thesiger, one of the judges of the English Court of Appeal, died October 20th, suddenly and unexpectedly, at the age of forty-two. He was the third surviving son of the first Lord Chelmsford. He was educated at Eton and at Christ Church, Oxford, and was called to the bar in 1862. In 1873 he received a silk gown from Lord Selborne. At first his leading business was mainly confined to parliamentary committees and to compensation cases, but he soon acquired a leading business at Nisi Prius, and was extensively employed in the House of Lords, and he acquired a practice worth £10,000 annually. He served upon the Extradition Commission and the Fugitive Slave Law Commission. In 1877

he was appointed Attorney-General to the Prince of Wales, and two months afterward was appointed a Lord Justice of Appeal, and was sworn a member of the Privy Council. As he was then only thirty-nine years old, the appointment was severely criticised, but he soon justified Lord Cairns' selection. His judgments were carefully prepared and well reasoned, and his courteous manner rendered him a general favorite with the bar. The Law Times says: "A brilliant career, which those who knew the Lord Justice well anticipated would be crowned with the highest honors attainable by a lawyer, has been abruptly terminated; but not until abundant evidence has been furnished that he possessed all the qualifications of a judge. At the bar Mr. Alfred Thesiger was distinguished for his grasp of detail, his lucidity of statement and the perfect fairness with which he stated his case. He appreciated with rapidity and accuracy points of law when they were presented to him, and without difficulty he laid before the court the whole of his case in logical order. As Lord Justice the powers which he possessed shone conspicuously. He was peculiarly fitted for the high order of judicial work provided by a court of appeal. His judgments are models of clearness, free from verbosity-which too frequently covers confusion of ideas and couched in language singularly apt and judicial. His demeanor to the bar was that of a courteous gentleman who knew that the business of a judge is to hear arguments, not to interrogate or interrupt counsel. That he felt his position- a judge of appeal when not yet forty-to be delicate and difficult, we believe; and in the present year, when congratulating a county court judge on his appointment, he expressed a doubt whether the office of the latter was not more to be envied than that of a Lord Justice. After three years of conscientious and valuable labor he has been cut off. The country, the law and the legal profession thereby sustain a loss which it is difficult to exaggerate. Judicial intellects are rare. Lord Justice Thesiger promised in the progress of years to develop a judicial intellect of the highest order." The Law Journal says: "He was not one of those of whom there have been many examples in English legal history- -men who made their way, in spite of adverse circumstances, by force of genius and perseverance alone. He was rather one who, being placed in the best situation for success, was quite equal to the situation, and succeeded. He would not have succeeded had he not possessed great industry and conscientiousness. Those who sent their briefs to Mr. Thesiger knew that the law and facts would be mastered by him. He was not a man of great quickness of parts; but he knew his defects. He acquired by labor what others had by intuition, and was able to equal and sometimes beat them in the race. He had not the faculty of picking up facts as the case proceeded, and perceiving the law as if by intuition; but by hard work he made himself practically almost as effective a forensic ally as if he had been gifted by nature with these qualities. The process he pursued was in the highest degree creditable to his powers of application and self-constraint; but it required great bodily and mental exertion. Without any wild theorizing, it may well be supposed that under this strain the machine wore out. The rest which the bench supplied-coming, although it did, much earlier than any one born under inferior auspices could have expected was not sufficient to restore the balance. He was not long enough on the bench to make a judgment of his judicial capacity possible. The moral qualities which had served him so well at the bar asserted themselves in the higher position. He was patient, dignified and painstaking. It fell to his lot to prepare several of the judgments of the Court of Appeal in the cases in which he took part, and they are examples of close reasoning and clear expression. He also exhibited great independence of judgment."

CORRESPONDENCE.

LEGAL NOTICES IN SUNDAY NEWSPAPERS.

Editor of the Albany Law Journal:

In reply to the question of "M," of Cleveland, whether a constructive service of legal process by publication in a Sunday newspaper is good, I send the following cases: If a publication of a notice is, by statute, required to be made for any number of days less than a week, a publication on Sunday as one of such days is invalid (Scammon v. Chicago, 40 Ill. 146; Sewall v. St. Paul, 20 Minn. 511; see Excelsior Ins. Co. case, 16 Abb. Pr. 8; State v. Wheeler, 64 Me. 532); but if the number of days be more than a week, neither its publication on the intervening Sundays (Taylor v. Palmer, 31 Cal. 240; Miles v. McDermott, id. 271; Carpenter v. St. Paul, 23 Minn. 232), although Sunday may be the first day of such publication (Cleland v. Tavernier, 11 id. 194), or the last (Savings Society v. Thompson, 32 Cal. 347), nor its omission on such intervening Sundays (Kellogg v. Carrico, 47 Mo. 157) will avoid its legality; nor will there arise any presumption of law that such notice was published on Sunday (Jenks v. Chicago, 48 Ill. 296), so, a thirty days' notice of sale was held to be good, although one of the three notices was posted on the inside of a post-office door, such office being open only for two hours on Sunday (Graham v. Fitts, 53 Miss. 307; see Osgood v. Blake, 1 Fost. 550).

A contract for a Sunday advertisement is void. Smith v. Wilcox, 19 Barb. 581; 25 id. 341; 24 N. Y. 353; Sheffield v. Balmer, 52 Mo. 474. Whether there can be a waiver of such irregularity in process - Morgan v. Johnson, 1 H. Black. 628; Taylor v. Phillips, 3 East, 155; Vanderpoel v. Wright, 1 Cow. 209; Wright v. Jeffrey, 5 id. 15; Gould v. Spencer, 5 Paige, 541; Pierce v. Rehfuss, 35 Mich. 53; Rheem v. Carlisle Bank, 76 Penn. St. 132.

A mistake in dating process, etc., on Sunday may be amended. Boyd v. Vanderkemp, 1 Barb. Ch. 273; York v. Ackerman, Penning, *900. See, also, Cotton v. Huey, 4 Ala. 56; Marshall v. Russell, 44 N. H. 509; Haines v. McCormick, 5 Ark. 663. J. H. S.

TRENTON, N. J., Oct. 30, 1880.

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of New York; James v. Cowing; Sprague v. Hosmer; The Philadelphia and Reading Coal and Iron Company v. Hotchkiss.-Order affirmed, and judgment absolute for respondents on stipulation, with costs - Brush v. Barrett; Mason v. Ludington; Dean v. De Wolf; Hewer v. Dannenhoffer.-Judgment reversed and judgment absolute for plaintiff on submission, with · Faulkner v. Hart.- Judgment of General Term reversed, and that of Special Term affirmed, with costs-- Ritch v. Smith.- - Order affirmed, with costsMonroe v. The Tradesmen's Fire Insurance Company. -Appeal dismissed, with costs- Elwood v. Roof; People ex rel. Waldman v. Police Commissioners of New York.

costs

NOTES.

HE November number of the American Law Review

Tentatus leading articles by William A. Maury on Validity of Statutes authorizing the accused to testify, and by Ernest Howard Crosby on Imputed Contributory Negligence of Third Persons. Mr. Crosby lays down three rules; first, contributory negligence of third persons does not constitute a defense unless such negligence is to be imputed to the plaintiff; second, the contributory negligence of a third person, who was guilty thereof as the agent of the plaintiff, must be imputed to the plaintiff; third, a plaintiff, who derives his cause of action from an injury done to a third person, is chargeable with the contributory negligence of such person. In the October number of the Southern Law Journal and Reporter is a leading article by Frank Fuller on Eloquence of the Bar, and a sketch, by J. M. Whitehead, of Benjamin F. Porter, deceased, once reporter and afterward judge of the Alabama Supreme Court. Also an excellent sketch of the late Judge Manning. -The second volume of the Federal Re

porter, by the West Publishing Co. of St. Paul, contains causes decided from May to July, 1880, covering 1,000 pages. It is a well-executed and very valuable publication, and little short of indispensable to every well-provided lawyer.

Vice-Chancellor Bacon, the oldest of the English judges, was raised to the Bench in 1870, and his present age is 82. The following are the particulars relating to the other judges:

Baggallay, L. J. Bramwell, L. J.

Grove, J. Hall, V. C.

THE following decisions were handed down Tuesday, Hannen, J

Nov. 9, 1880:

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Brett, L. J..

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Cockburn, L. C. J

1856

W. J. CULVER.

Coleridge, L. C. J..

1873

Cotton, L. J..

1877

Denman, J..

1872

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Fry, J...

1877

1871

1873

1868

Hawkins, J.

1876

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Judgment affirmed with costs-Hart v. Taylor Solinger v. Earle; Foose v. Whitmore; Wilson v. Lawrence; Hooley v. Gieve; Roe v. Barker; Ormes v. Dauchy; People ex rel. New York Elevated Railroad Company v. Commissioners of Taxes of New York; The Lacustrine Fertilizer Company v. The Lake Guano and Shell Fertilizer Company; Hunt v. Purdy; Frieberg v. Branigan, People ex rel. Westray v. The Mayor of New York; Lowenstein v. Flauraud; Pierson v. Morch; Van Beil v. Prescott.- Judgment reversed and new trial granted, costs to abide event - Pardee v. Treat; Pakalinskey v. The New York Central and Hudson River Railroad Company; Hatch v. The Mayor, etc.,

Lindley, J..
Lopes, J..
Lush, J..

Malins, V. C...
Manisty, J..

Pollock, B.

Phillimore, Sir R.

Stephen, J.

Bowen, J..

45

From this list it will be seen that there are eight judges who have attained seventy years and upwards, and eight whose age exceeds sixty.

The Albany Law Journal.

SOME

ALBANY, NOVEMBER 20, 1880.

CURRENT TOPICS.

To

OME one has kindly sent us a recent number of the Daily Memphis Avalanche. We opened the sheet with some trepidation, for the reputation of the newspaper in this part of our country had made us apprehensive of some concealed Greek fire, dynamite, or other explosive or inflammatory substance. our surprise we found the Avalanche a very calm and dignified journal, uttering political sentiments which might well have emanated from the New York Tribune. It also brought us an item of legal news which argues that at least in some parts and in some courts of the South, colored folks have rights which white people respect. Jane Brown, a colored woman, bought a ticket entitling her to a first-class passage from Corinth to Memphis, on the Memphis and Charleston railroad. She took her seat in the ladies' car; the conductor ordered her to go forward into a smoking and emigrant car; she refused to go, and thereupon she was ejected with great violence. She brought suit for damages in the Federal Circuit Court, and a jury of white men awarded her $3,000. The defense was first, that the plaintiff was an unchaste person; second, that under the law of Tennessee a carrier may refuse to carry any person at pleasure. It was conceded that on the occasion in question her conduct was proper, and that the railroad company had no regulation making discrimination on account of color.

The statute in question abrogated "the rule of the common law giving a right of action to any person excluded from any hotel, or public means of transportation, or place of amusement." It also enacted that "no keeper of any hotel or public house, or carrier of passengers for hire, shall be bound to entertain, carry, or admit, any person whom he shall, for any reason whatever, choose not to entertain, carry, or admit, to his house, hotel, carriage or means of transportation, or place of amusement; nor shall any right exist in favor of any such person so refused admission; but the right of such keepers of hotels, carriers of passengers and keepers of places of amusement to control the access and admission or exclusion of persons to or from their public houses, means of transportation and places of amusement, shall be as perfect and complete as that of any private house, carriage, or private theater, or place of amusement for his family." Judge Hammond charged the jury that this act of the Legislature, so far as it abrogated the common-law right of action for wrongful exclusion from railroad cars on roads running between two or more States, was unconstitutional, because it was a regulation of commerce between the States, which the Legislature had no right to make, the exclusive right to make it being by the Constitution of the United States in VOL. 22.- No. 21.

Congress. He charged the jury on the question of the plaintiff's character for chastity, that the same principles of law were to be applied to women as to men in determining whether the exclusion was lawful or not. That the social penalties of exclusion of unchaste women from hotels, theaters, and other public places could not be applied to common carriers; that they had a right to travel in the streets and on the public highways, and other people who travel must expect to meet them in such places; and as long as their conduct was unobjectionable while in such places, they could not be excluded. The carrier is bound to carry good, bad, and indifferent, and has nothing to do with the morals of his passengers, if their behavior be proper while travelling. Neither can the carrier use the character for chastity of his female passengers as a basis of classification, so that he may put all chaste women, or women who have the reputation of being chaste, into one car, and those known or reputed to be unchaste, in another car. Such a regulation would be contrary to public policy, and unreasonable. It would put every woman purchasing a railroad ticket on trial for her virtue before the conductor as her judge, and in case of mistake, would lead to breaches of the peace. It would practically exclude all sensible and sensitive women from travelling at all, no matter how virtuous, for fear they might be put into, or unconsciously occupy, the wrong car. So far as heard from, therefore, Jane Brown's body is marching on.

A correspondent asks us what we say as to the case of Reed v. N. Y. Cent. R. R. Co., 45 N. Y. 574, in view of our third conclusion in regard to declarations of injured parties, ante, 365. That conclusion was as follows: "Complaints and statements of the injured party as to his present physical condition, although subsequently to the occurrence and indeed after suit is brought for the injuries, are admissible, whether made to a physician or to one who is not an expert.' In the case referred to, the syllabus states that it was held that "the evidence of the plaintiff, in his own behalf, that at the time this labor was being performed, he declared to a person casually present, and with whom he had no business relation, that he felt ill, was inadmissible, either to controvert the defendant's proof or to show statements of his own out of court consistent with his testimony." We say that this is not inconsistent with our conclusion: first, because it was the plaintiff's own testimony as to what he had said, and not the testimony of others as to what he had said; or as Judge Allen put it, it was "the unsworn statement of the plaintiff;" it was not the best evidence from his own mouth; "the plaintiff," said Judge Allen, "was a competent witness to prove the state of his health at the time," "and it was not necessary to resort to other and inferior evidence; and so long as his sworn statements were admissible, his unsworn declarations should not have been received." This certainly is as far as the decision could go, for it did not involve the proof of the declarations by the testimony of third persons. This, we think, serves to distin

guish the case. But, second, at all events the decision was not put on this ground by a majority of the court, for only three judges concurred in this view, namely, Allen, Grover and Rapallo, while Folger, J., was for reversal on another ground, in which Rapallo, J., also concurred; Church, C. J., and Peckham, J., dissented, and Andrews, J., did not vote. So the case is not of much authority on this point. Third, if Judge Allen meant to exclude proof by third persons, not expert, of the plaintiff's declarations, his theory that there is no necessity for such evidence because the plaintiff himself could testify as to his state of health, we think, is erroneous, and herein we agree with the dissenting judges.

As our Court of Appeals are about to take possession of their chamber in the new capitol, we are reminded that new accommodations for our lower courts are soon to be provided in the city hall, which is to take the place of the old edifice burned last winter. We know nothing of the plans of the new building, but we hope that every thing will not be sacrificed to exterior and interior display, but that we shall have rooms where people can see, breathe, and hear. It is of slight consequence that nobody can be heard in the assembly chamber of the new capitol, but hearing is of great consequence in a court room. Light and ventilation too are important matters. In recent architecture, while there is a decided revival of good taste, there is a tendency to sink the utilitarian in the esthetic, and to give us beautiful medieval caves where we should have simple rooms. Our profession demand a little consideration for themselves, as well as for the judges, jurors, suitors, and spectators, and must have natural light enough to see to read at mid-day, air that will not poison, and acoustic properties that will enable the occupants of the rooms to hear and be heard without painful effort. Let the money be spent on these points, rather than on carvings, paintings, tilings, and costly masses of materials.

However men feel about Mr. Hewitt's conduct, as a politician and a man of honor, in the Chinese letter case, there can hardly be any difference of opinion among the bar as to the rebuke administered to that gentleman by Judge Davis in his recent decision. It seems to us a very unnecessary and undignified, not to say improper, performance. If Mr. Hewitt was guilty of any crime, it was Judge Davis' duty to hold him for that crime. If he had not been guilty of any crime, Judge Davis had no duty in the premises, with respect to him. The people have not yet constituted Judge Davis their Cato, nor their model of deportment. He has as little right to promulgate his opinion on such points from the bench as we have to do so in this JOURNAL. This is not the first time, even in this case, that he has thought it important to the public to "put himself on the record," from the bench, on purely public or political affairs. We are glad to know that in this instance his conduct has not cost the victim any thing. We have as high a respect for

Judge Davis' virtues, talents, and public services as anybody, but this partisan exhibition on the bench is not greatly to his credit. If he wants to denounce Mr. Hewitt's conduct, let him hire Cooper Institute, or publish a pamphlet. This is his right, and he would have plenty of sympathizing hearers or readers. But the present is not the way to commend himself to men who love fair play and abhor judicial partisanship. It is entirely outside the much-abused judicial privilege of commenting on the conduct and demeanor of witnesses. propriety of this present utterance is emphasized by the fact that the judge committed an important error in stating the testimony upon which he arraigns Mr. Hewitt, and is forced to descend to an explanation in the newspapers. The public do not like this sort of conduct in a judge. The physical, moral, and political world will continue to revolve very well without the interference of judicial busybodies.

The im

The meeting of the New York State Bar Association on Tuesday last was even more slenderly attended than usual, and the exercises, on the whole, were of less than ordinary interest. Even the supper in the evening did not attract the usual number. We have concluded that the lawyer is not a conventional animal. The principal matter of interest in the morning session was an elaborate report by Mr. Delafield, of New York, denouncing legislative discrimination in favor of our law schools, and seeking to put the Harvard, Yale, and Virginia law schools The on the same footing in our State as our own. former branch of his suggestions was adopted, the latter discarded. While we are by no means strenuous about having law school graduates admitted on motion, believing that the courts are quite at liberty to amuse themselves with their present farcical examinations, yet if there is an advantage in a law school education over that to be derived from mere reading in an office, it would seem fair to make some discrimination, in point of the term of study, in favor of the law schools. We regretted to hear Mr. Delafield read the sentence in the late Chief Judge Church's letter, to the effect that law school managers run the schools simply to make money. declaration is a great injustice to such men as Judge Dwight and Judge Dillon, of Columbia, and the late Senator Harris and Amos Dean, and Judge Parker, formerly of the Albany Law School; and especially to the late Chief Judge's eminent_colleague, the late Judge Allen, who used to come down from the bench to deliver lectures before the Albany Law School.

That

The annual address, by Mr. George W. Biddle, of Philadelphia, was a vigorous, exhaustive, and admirably expressed essay on the proper office and limitations of Retrospective Legislation. Mr. Biddle produced an excellent impression upon our bar, by his learning, modesty, and amenity, and his address was listened to with great interest and profit. To his remarks, at the supper, in favor of a substantial life tenure for judges, we cannot give our adhesion,

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