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commits a murder, she would be presumed to have acted under coercion, it was not necessary to deter mine, for there was evidence tending to rebut such a presumption. The effect of this case is not accu rately stated by Mr. Richards, 13 Crim. Law Mag. 47. People -v. Seiler, 77 N. Y. 411, was a case of larceny, and the presumption was rebutted. State v. Boyle, 13 R. I. 537, was a case of selling intoxicat ing liquors. Mr. Wharton's authorities are equally indecisive. Regina v. Smith, 8 Cox C. C. 27, was a case of serious beating by the husband with a stick; the wife under coercion wrote letters inviting the complain ant to the place, pretending that she was a widow, and met him there dressed as a widow, but did not aid the beating. A conviction of her was re versed. Regina -v. Wardroper, 8 Cox C. C. 284, was an indictment for jointly receiving stolen goods. A new trial was granted because of the exclusion of evidence that the wife received the goods from her husband. Williams, J., observed : "I am not pre pared to say that the liability of a wife diners from that of any other person, unless there is some evi dence to show that she was acting under his control." The decision in Davis v. State, 15 Ohio, 72, is not correctly stated in the syllabus, which is as follows : "If a wife join with her husband in the commission of a crime less than murder, she is presumed to act under the coercion of her husband, and in law is not guilty; but the fact of coverture must be clearly made out by proof." The charge was arson. All that the Court said on this point was : " It is claimed that she was the wife of William Davis, and joined with him in the commission of the crime, and therefore was not pv guilty, as the law presumes that she acted by the com mand and coercion of her husband. The legal princi ple claimedfor her benefit is admitted; but the fact of coverture, necessary to bring her within its operation, was not established." The words which I have itali cised could in no event be extended beyond the par

ticular crime of arson in question, and could not be held to apply to all crimes less than murder; but the principle thus "admitted" was clearly obiter. The point was very slightly touched upon in the argu ments. The case of State -'. Parkerson, i Strobh. 169, is not in point, for the charge was but assault and bat tery, and the point decided was that husband and wife were properly indicted jointly therefor, as the presumption of coercion was rebuttable. The Court did say that the wife would not be punishable "if she committed a bare theft or even a burglary by the coercion of her husband."

VALUE OF DOG. — A novel use of a dog was shown in Heiligman v. Rose, 81 Tex. 222; 13 L. R. A. 272, an action for killing two dogs of the Newfound land breed, which resulted in a verdictof $75. The court held that it was not essential to show market value, and sustained the verdict on the proof that one of the beasts " was trained to signal the arrival of any person at appellee's, who could tell from his look if the person was man, woman or child." That certainly was a shrewd dog, but a shrewder owner, and it vould seem less trouble to look at the person than to scrutinize the dog's face.

DEFINITIONS. — In Wadsworth v. Marshall (Maine,) 32 L. R. A. 888, a statute requiring reasonable notice of setting off a blast to persons "approaching," is held to apply to persons who have just passed the point nearest the blasting, if they are notât a safe dis tance therefrom. So under the beautiful " elasticity of the law" "approaching" may mean "going away from." But the decision is right. We know of one case where a custom was held probable to show that " white " meant " black." Nothing could be more elastic than that.