According to law, no child under 14 years of age can be legally employed in any manufacturing or mercantile establishment. The Census disclosed the fact that there were 394 children illegally employed, of whom 276, or 70.05 per cent, were in the cities, and 118, or 29.95 per cent, were in the towns. Children above 14 and under the age of 16 years cannot be legally employed unless provided with a school certificate issued by the proper authorities. The number of children 14 and 15 years of age employed in the Commonwealth on May 1, 1905, was 21,995, being 98.24 per cent of 22,389, the whole number of children under 16 years of age reported as being at work. Those children 14 years of age numbered 5,449, of whom 4,004, or 73.48 per cent, were employed in the cities and 1,445, or 26.52 per cent, in the towns. Those 15 years of age numbered 16,546, of whom 12,076, or 72.98 per cent, were employed in the cities and 4,470, or 27.02 per cent, in the towns. The whole number of children employed in the State at the time the Census was taken, May 1, 1905, was 22,389, of whom 16,356, or 73.05 per cent, were employed in the cities and 6,033, or 26.95 per cent, in the towns. Of the total number of children at work, or 22,389, 15,914, or 71.08 per cent, were native born and 6,475, or 28.92 per cent, were foreign born; the males numbered 13,142, or 58.70 per cent, and the females, 9,247, or 41.30 per cent. Of the 13,142 males, 9,635, or 73.31 per cent, were native born and 3,507, or 26.69 per cent, were foreign born; of the 9,247 females, 6,279, or 67.90 per cent, were native born and 2,968, or 32.10 per cent, were foreign born. Considering the entire population of the State on May 1, 1905, or 3,003,680, the number of children at work, or 22,389, represented 0.75 per cent (three-quarters of one per cent). Of the 751,152 persons engaged in domestic service (including housewives, housekeepers, and domestic servants), 786, or 0.10 per cent, were children 10 to 15 years of age; 13,156, or 1.75 per cent, were young persons 16 to 20 years of age. Of the 208,636 persons employed in trade, 4,027, or 1.93 per cent, were children 10 to 15 years of age; 30,052, or 14.40 per cent, were young persons 16 to 20 years of age. Of the 601,667 persons employed in manufacturing industries of all kinds, 14,157, or 2.35 per cent, were children 10 to 15 years of age, while 102,140, or 16.98 per cent, were young persons 16 to 20 years of age. Of 26,155 persons employed as farm laborers, 801, or 3.06 per cent, were children from 10 to 15 years of age, while 6,171, or 23.60 per cent, were young persons 16 to 20 years of age. In 1895, the children at work between 10 and 14 years of age numbered 5,535, being 0.22 per cent of the total population for that year. The number of children at work, as determined by the State Census of 1905, between the ages of 10 and 13 was 394, or 0.01 per cent of the total population, or 3,003,680. The number of children at work in 1905 from 10 to 14 years of age was 5.843, or 0.19 per cent of the total population in that year. Comparing the number of children employed in 1905 from 10 to 14 years of age with the number employed in 1895, we find a reduction, as compared with the total population, of 0.03 per cent. The actual increase, numerically, was 308, but when compared with the total population the number employed in 1905 represents a reduction. Considering that during the past 10 years the population has been increased more than one-half a million, this increase consisting largely of immigrants, even the small reduction shown must be considered as a favorable exhibit. A STATE LIFE INSURANCE SYSTEM. In a recent article in Collier's Weekly, Mr. Louis D. Brandeis, of Boston, called attention to the great amount devoted to expenses by what are known as industrial insurance companies, and suggested that the charters of the savings-banks be so enlarged as to allow them to do an insurance business, contending that they could take on this new function and supply the insurance desired by workingmen at a much lower rate than is charged by the industrial companies. Mr. Ernest Howard, in the October, 1905, number of the International Quarterly, published in New York City, considered the subject of a State life insurance system. Mr. Howard's article was reviewed in the American Monthly Review of Reviews for November, 1905, and the editor of the Review suggested a plan which would enable a State to enter the insurance field. He said: The State of Massachusetts, for example, having a competent insurance bureau already in operation, might constitute this bureau a home office which would establish branches in every considerable city and town, all being placed in charge of officials and clerks on small salaries. In comparing the existing companies with the present savings-banks, he said further: In seeking to arrive at the approximate cost of such State insurance, Mr. Howard institutes an interesting comparison between insurance companies and savings-banks. The proposed system of State-directed insurance would be similar to the savings-banks as now conducted by disinterested trustees and salaried officials responsible to a directing State authority, on the non-competitive principle and with the element of profit excluded. Four of the largest of the Massachusetts savings institutions are compared with four regular life insurance companies of the State which are among the soundest and most conservative old-line companies in America. The table presented by Mr. Howard in his article is given below: These two classes of institutions are very similar in a financial sense. Neither is engaged in money-making beyond the interest improvement in invested funds. Both are engaged in receiving, investing, guarding, and distributing or returning money. Both perform the function of conservator of the social economy against the time of need or loss by death. Nevertheless, the remarkable fact appears that the costs of conducting the one class of institution are nearly twenty times greater than those of the other, whether considered in relation to gross income or the assets or trust funds in charge. And it is worthy of further remark that the single expense item of salaries of officers and home-office employees of the four life companies for the year in question ($461,292) is more than double the entire expenses of the four banks. After a further comparison of expenses, Mr. Howard concludes: Here, then, is the clear practicability of reducing the charges of insurance by from 16 to 20 per cent, without affecting in the slightest the additions to and divisions from surplus. . . . The magnitude of saving on such a scale, when extended over large bodies of policy-holders and for stretches of years, would be incalculable. Moreover, endowment or policies with the savings-bank feature would in this case have a greatly enhanced desirability; for, as it is, such a policy involves the absurdity of turning savings from a bank of low expense ratio to an insurance company with a ratio many times higher. As a final suggestion, the editor of the Review says: "The New Zealand method might be adopted, by which the State would offer insurance in open competition with private companies. It would then be a case of the survival. of the fittest."" RECENT COURT DECISIONS RELATING TO LABOR. Injunction - - Picketing — Boycotting. In the recent case of Butterick Publishing Co. v. Typographical Union No. 6 et al., 50 Misc. 1, the New York Supreme Court, Special Term, held that: (1) The employees of a publishing company on strike and the local labor union of which they are members are within their legal rights in publishing circulars setting forth the circumstances of the strike and requesting their friends to withhold their patronage from the company, and an injunction may be granted only from resorting to threats, intimidation, force, or fraud in their relations with the customers of the publishing company, and the publication of such circu-| lars may not be restrained upon the ground that they contain innuendoes of a libelous character: (2) while the right of striking employees "to picket" their employer's place of business and to strive by reason, argument, and proper appeal to win over those who have taken their places at work is well established, the striking employees and the local labor unions of which they are members may be restrained from resorting to any threats, intimidation, force, or fraud in their relations with the employees who took their places; (3) the verb "to boycott "does not necessarily signify to employ violence, intimidation, or other unlawful coercive means, but may correctly sig nify to combine in refusing to have business dealings with another until he removes or ameliorates conditions deemed inimical to the welfare of the members of the combination, or some of them, or grants concessions which are deemed to make for that purpose; as such a combination may be formed and held together by argument, persuasion, or by the "touch of nature" and accomplish its purpose without violence or other unlawful means, it cannot be said that "to boycott" is to offend the law; (4) where the plaintiff's right is doubtful the court will not grant an injunction pendente lite containing the same relief that would ultimately be granted if the plaintiff succeeded upon the trial of the action. * Injunction Peaceable Enticement away of Employees not Unlawful. In the recent case of Iron Molders Union et al. v. I. & E. Greenwald Co., before the Superior Court of Cincinnati, O., General Term, it appeared that in September, 1904, an injunction was issued restraining the union, its officers, and members, among other things, from all interference with the business of the Greenwald Co. In August, 1905, the company brought charges against two members of the union for contempt, alleging that they had disobeyed, resisted, and violated the injunction by inducing two employees to break their contracts with the company, and had interfered with other employees in trying to induce them to leave company's employ. The Court in Special Term found the members of the union guilty of unlawful persuasion and violation of the terms of the restraining order. The General Term of the Superior Court reversed this decision and held that: (1) A court of record has complete jurisdiction and inherent power to punish for contempt in the case of an employer who complains of interference with his business and irreparable injury thereto by strikers and members of a labor union; and the only question on review of proceedings in contempt against strikers is whether the evidence sustains the judgment which was rendered. (2) Where the record shows that the acts of which the defendant strikers and their leaders have been found guilty consisted in peacefully enticing employees to leave their employment when not under contract to remain, and in giving them railroad tickets and money for traveling expenses to go to another city with their families, a finding that such conduct was unlawful persuasion and in contempt of a previous order of court which enjoined against unlawful persuasion will be reversed on the ground that the defendants were acting within their rights. Judge Hoffheimer in rendering his opinion stated that if the members of the union who were adjudged guilty of contempt had violated any section of the decree it was this paragraph: "Also from compelling or inducing or attempting to compel or induce by threats, intimidation, force, violence or unlawful persuasion, any of the employees of the I. & E. Greenwald Co. to leave its service." Continuing he said: "The scope of the injunction, therefore, is directed against unlawful persuasion, and it is a violation of this injunction with which the men stood charged. In considering the evidence, therefore, the sig nificance or treatment of the term 'unlawful persuasion is at once involved. "The term unlawful persuasion has a technical legal signification. What constitutes unlawful persuasion in some jurisdictions is not unlawful in others. For example, we find fre quently cited in the decisions the case of The Taff Vale Railway Co. et al. v. Amalgamated Societies of Railway Servants (1901), Appeal Cases H. L., 426, as an exposition of the English idea. Indeed, we are cited to it in this case as an expression of the highest English court upon the subject. In that case the injunction restrained the defendant labor union, its servants, agents, and others acting by its authority from watching, or causing to be watched or beset, The Great Western Railway station at Cardiff, or the works of the plaintiff, or any of them or the approaches thereto, or the place of residence or any place where they might happen to be, or any workman employed or proposing to work, for plaintiff, for the purpose of persuading or otherwise preventing persons from working * For decision of Superior Court, Special Term, see Labor Bulletin, No. 39, January, 1906, p. 30. for the plaintiff or for any other purpose except merely to obtain or communicate information, and from procuring any person who had or might enter into any contracts with the plaintiff to commit a breach of such contracts. This injunction, it appears, was sustained by the House of Lords without dissent. Nor "Thus it is seen that this celebrated case enjoins persuasion even by peaceful means. does this case stand alone. But the principle of this case is not generally accepted by the American courts. In 6 Pomeroy's Equity Jurispru dence, Par. 595 (edition just published, 1906), I find the following: "The American courts generally agree that interference with the employee's right to continue in employment, or the employer's right to have such continued employment, not under contract, where such interference is by direct coercion or intimidation of the employee, is ground for injunction. But when the interference with these rights is by persuasion and peaceable means, it is not generally in the American courts considered unlawful, and an injunction will not be given.' See Fletcher Co. v. Association of Machinists (N. J. Ch.), 55 Atl. 1077; Foster v. Retail Clerks' Association, 39 Misc. 48; Bohn Mfg. Co. v. Hollis, 55 N. W. 1119; Rogers v. Evarts, 17 N. Y. Supp. 264; Reynolds v. Everett, 144 N. Y. 189. "The authority cited points out that in England the injunction extends to interference by persuasion (citing Taff Vale Railway Co. V. Amalgamated Societies of Railway Servants, supra), and adds: But this extension rests upon an act of Parliament.' (Act of 1876.) In examining the status of labor unions in our own State, we find that the policy of our law favors them. Sec. 4364-68 Revised Statutes of Ohio is as follows: It shall be unlawful for any individual, or member of any firm, or agent, officer or employee of any company or corpora tion to prevent employees from forming, joining and belonging to any lawful labor organization, and any such individual, member, agent, officer or employee that coerces or attempts to coerce employees, by discharging or threatening to discharge from their employment or the employ of any firm, company, or corporation because of their connection with such lawful labor organization, shall be guilty of a misdemeanor, and upon conviction thereof in any court of competent jurisdiction shall be fined in any sum not exceeding one hundred dollars or imprisoned for not more than six months, or both, in the discretion of the court.' "By necessary implication the labor union has the right to invite members to join the unions. This being so, if the persuasion is peaceful (that which the law countenances), what difference does it make what the motives of those who engage in such persuasion may be? . . . "It can make no difference what the evidence may show the motives of Hinnenkamp and O'Leary to have been in persuading East and Reid to join the union and leave the service of the Greenwald Co. The question of motive is immaterial and cannot be considered. The testimony substantially shows that the two employees, East and Reid, were induced by Hinnenkamp and O'Leary by means of argument and bribes (railroad tickets and expenses) to join the union and thus leave the service of the I. & E. Green wald Co. The men were not under contract with the I. & E. Greenwald Co. Mr. Greenwald himself testifies that the men were not under any particular agreement (Record, p. 4), and that they received wages of three dollars a day. There was no force, no violence, no intimidation in what plaintiffs in error did. . . . Under the circumstances of this particular case the persuasion used was lawful. The evidence, therefore, did not warrant conviction, and the finding of the court below was therefore erroneous." Eight-hour Law of the United States does not apply to Work on Naval Vessels built in Private Shipyards. The Attorney-General of the United States recently approved a decision rendered by Solicitor-General Hoyt, in reply to a query by the Secretary of the Navy as to whether the Act of August 1, 1892, entitled "An Act relating to the limitation of the hours of daily service of laborers and mechanics employed upon the public works of the United States and of the District of Columbia" (27 Stat. 340), applied to labor under contract for the construction of naval vessels. The act provides: "That the service and employment of all laborers and mechanics who are now or may hereafter be employed by the Government of the United States, by the District of Columbia, or by any contractor or subcontractor upon any of the public works of the United States or of the said District of Columbia is hereby limited and restricted to eight hours in any one calendar day, and it shall be unlawful for any officer of the United States government or of the District of Columbia, or any such contractor or subcontractor whose duty it shall be to employ, direct or control the services of such laborers or mechanics, to require or permit any such laborer or mechanic to work more than eight hours in any calendar day except in case of an extraordinary emergency." Section two of the act provides a penalty for violation by an officer or contractor, and section three excepts from the operation of the act contracts entered into prior to its passage. The Attorney-General said that the question is, in effect, whether the phrase "public works of the United States" as used in the Act of August 1, 1892, comprehends vessels under construction for the navy by contract with builders at private establishments over which the Government has no executive control or supervision. It seems that various vessels are under construction in accordance with the requirements of the act of August 3, 1886 (24 Stat. 215), and as authorized by different annual appropriation acts under the heading "Increase of the Navy;" and contracts in the usual form, postponing acceptance of the vessel and complete title in the Government until final delivery, have accordingly been made for the construction of a number of such vessels in private establishments of shipbuilders. Attorney-General Griggs, construing the act of August 13. 1894 (23 Stat. 278), "for the protection of persons furnishing material and labor for the construction of public works," held that that act does not refer to contracts for the construction of naval vessels. He said: "The object of the act was to afford a better method for enforcing against the contractor the claims of laborers and material men who had done work or furnished material upon property actually belonging to the United States, such as public |