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147 NOTES. 1 47 currently, as at this school, instead of the former Columbia method of taking up one subject until finished and then passing on to the next. The New York Law School, on the other hand, has been organized this year with a view to perpetuating the old Columbia or so-called u Dwight " system of instruction (which is little more than the dis- carded Harvard method as pursued by Professors Parsons, Washburn, and others). Its dean is Professor Chase, late of Columbia, and its faculty is composed of the instructors who were associated with Pro- fessors Dwight and Chase. The school is situated in the Equitable Building, in the business centre of the city,' with the various courts near at hand, in the midst of many law offices, and having access to the law library in the building, comprising about thirteen thousand volumes — a library a little more than half the size of the Columbia law library. The course is to cover two years, and is so arranged that members of the school can spend each morning or afternoon in a law office, and this they are distinctly encouraged to do. Text-books will be used entirely, with occasional references to cases by way of illustra- tion. Here, as formerly at Columbia, each subject will be studied un- til completed, when the next subject will be taken up, and so on to the end of the year. The aim of this school is to give a thorough, practi- cal legal education, to enable a man, at the end of two years, to pass his bar examinations, and enter on the practice of his profession. The theory, history, and science of the law are disregarded, as being rather food for the jurist than for the practical lawyer. A discussion of the comparative merits of these two most opposite methods would be unprofitable. Imbued as we are at this school with the methods and ideas to which Professor Langdell has given his name, our sympathies must naturally be with Professor Keener and his work. Whatever may be the advantages of the system adopted by the New York Law School, experience has shown that in the long run the thor- ough, systematic study of legal principles which the Langdell method requires fully as well enables its votaries to cope with the serious prob- lems of the law. Legal Detriment in Contracts. — The Court of Appeals of New York has lately rendered a decision in the case of Hamer v. Sidway? reversing a decision of the Supreme Court. The facts of this case briefly were that the defendant's testator offered to the plain- tiff the sum of five thousand dollars, if he would refrain from smoking and drinking liquor until he became of age. The plaintiff performed the condition and, after asking for the money, brought this action. The Supreme Court decided in favor of the defendant, on the ground that the plaintiff had incurred no detriment, it being no disadvantage to refrain from habits which " are not only expensive but unnecessary and evil in their tendency." When the decision was reported, the Review, Vol. 4, page 237, pointed out that the court had misunderstood the meaning of the term "legal detriment." We contended that the term meant the giving up of a legal right, and that the plaintiff had done this. The judgment of the Court of Appeals is based on this definition. Parker, J., speaking of the defendant's contention that the plaintiff incurred no detriment, as what he did was really beneficial to him, 1 124 New York, 538.