Page:Hot Springs School District v. Sisters of Mercy Female Academy of Little Rock.pdf/4

500 In discussing a similar case in State v. Powers Hospital, 10 Mo. App. 263, the court said: "Does the fact that this institution derives some part of its revenue from paying patients exclude it from the benefits of the constitutional exemption from taxation? We do not see upon what reasonable grounds this can be said. Suppose that the community in charge of the hospital devoted themselves partly to some kind of manual labor, shoemaking for instance, in order to raise money for the purpose of furnishing medicine and necessaries and comforts to their patients, would not this be a charitable act? If they devote themselves partly to the care of paying patients, to defray the expenses of attendance upon the poorer patients who can not pay, this is surely an act of charity. Must we hold that if the community raise money purely by begging, their purposes are purely charitable; but if they work to support themselves whilst ministering to the sick, and to support the sick to whom they administer, the character of the charity is impaired? The fact of receiving money from some of the patients does not, we think, at all impair the character of the charity, so long as the money thus received is devoted altogether to the charitable object which the institution is intended to further."

In the case of County of Hennepin v. Brotherhood of Gethsemane, 27 Minn. 460, the court said: "A hospital, with the necessary grounds, free to all who are not pecuniarily able, and supported partly by private contributions and partly by fees from patients, but producing no profit, is a purely public charity."

In the case of Penn. Hospital v. Delaware Co., 160 Pa. St. 305, the court said: "Property which is used directly for the purpose and in the operation of the charity is exempt, though it may also be used in a manner to yield some return and thereby reduce the expenses."

To the same effect, see Sisters of Charity v. Township of Chatham, 52 N. J. L. 373; Mount Hermon Boys' School v. Gill, 145 Mass. 149; Episcopal Academy v. Philadelphia, 150 Pa. St. 574.

One of the witnesses here said that she had been a member of the Sisters of Mercy for forty years, that the whole object of the order was charity, and that their whole life was devoted to it. In response to the question, "This order, the Sisters of Mercy,