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96 96 HARVARD LAW REVIEW. poration"was quasi public, and the lease was void as ultra vires, and because it was an abandonment by the lessor of its duty to the public. Central Transp. Co. v. Pullman's Palace Car Co., 1 1 Sup. Ct. Rep. 478. Criminal Law — Contract for Alien Labor. — The defendant was indicted for having prepaid the transportation of aliens under contract to perform labor for him in the United States, contrary to 23 U. S. St. 333. Held, that the offence was not com- mitted unless there was a valid contract with the aliens. United States v. Edgar, 45 Fed. Rep. 44. Criminal Law — Murder — Resisting Unlawful Arrest. — Homicide done in resisting an unlawful arrest will not be reduced to manslaughter because of that fact, unless accused was aware at the time that the arrest was unlawful. In the absence of such knowledge, there is no reason for assuming the existence of sudden passion, which the law regards as naturally provoked when interference with personal liberty is wrongful and known as such. Drew's Case, 4 Mass. 391, explained and qualified. Ex parte Sherwood, 15 S. W. Rep. 812 (Tex.). Equity — Injunction — Interstate Commerce. — The complainants filed a bill for an injunction, alleging that they, as agents for dealers in another State, were engaged in selling liquor in original packages, and that by civil and criminal proceedings under the prohibitory law of the State, the defendants were seeking to break up and destroy complainant's business in violation of their rights under the Federal Constitution. There was no allegation that the defendants were insolvent, or were likely to do irrepar- able damage. Held, that the bill would not lie to restrain the criminal proceedings, as equity had no such power ; that it would not lie to enjoin the civil proceedings, as there was an adequate remedy at law. Hemsley v. Myers, 45 Fed. Rep. 283. [Compare Tuchman v. Welch, 42 Fed. Rep. 548.] Equity — Injunction — Wrongful Attachment. — Where the property wrong- fully attached is a stock of merchandise, which in connection with his business consti- tutes the whole of the owner's resources, he may have an injunction against closing his store and the sale of the goods, since trespass or replevin is not an adequate remedy, as damages are recoverable therein only for the value of the goods, and not for the destruction of his business. North v. Peters, 11 Sup. Ct. Rep. 346. This follows Watson v. Sutherland, 5 Wall. 74, 78, 79. Equity — Sale of Church Property for Debts. — A court may compel the sale of a church site and edifice to pay the salary of the pastor. Lyons et al. v. Planters' Loan &* Savings Bank, 12 S. E. Rep. 882 (Ga.). See ante, p. 91. Evidence — Account-Books. — Entries in the account-books of a corporation are not per se competent evidence on behalf of the corporation in an action against a director. Reversing 7 N. Y. Supp. 535. Rudd v. Robinson, 26 N. E. Rep. 1046 (N. Y.). Municipal Corporations — Buildings for Private Purposes. — Under a statute authorizing a city to appropriate public money for the erection of a hall to be used and maintained as a memorial to the soldiers and sailors of the War of the Rebellion, the city has no power to make an appropriation for the erection of a build- ing to be used in part by a certain Grand Army Post during its existence as an organi- zation, since that is not a public use. R~ittgma?t et al. v. City 0/ Brockton, 26 N. E. Rep. 998 (Mass.). Parliamentary Law — Powers of Presiding Officer. — The mayor of the city of Little Rock is by statute president of the Common Council. Plaintiff, a mem- ber of that body, being somewhat disorderly but not violent, was given by the mayor into the hands of the executive officer and expelled. Held, in an action for assault and false imprisonment, that he could recover. A presiding officer, by usage and the com- mon law, has no right of his own motion to put an offending member into custody unless actual violence is threatened. Thompson v. Whipple et al., 15 s. W. Rep. 604 (Ark.). Real Property — Rule in Shelley's Case. — A testator devised an estate to his son, "for and during the term of his natural life," and continued : " At the death of said son, I give and devise said lands in fee simple to the persons who would have inherited the same from the said son had he owned the same in fee simple at the time