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Dominicans were entrusted with the admin istration of the College as teachers; that at the time of its foundation, the Jesuits were the educators of Church as well as of State; that the administration entrusted to them and, subsequently, to the Dominicans, was subject to the ultimate control and direction

of the Crown; and that the right to appoint an administrator, and to provide for the con trol of the institution, was in the Govern ment of Spain, which right was vested in the United States Government 'by virtue of the Treaty of Paris.

LORD MANSFIELD'S UNDECIDED CASE IN THE SUPREME COURT OF THE UNITED STATES. BY FREDERICK. DE COURCY FAUST. THE Supreme Court of the United States Wing v. Angrave a welcome settlement of the perplexing and difficult problem, this is has recently had submitted to it for de the first occasion upon which the Supreme cision the interesting question of the distri bution of personal estates, where the owner Court has been called upon to review the law arid the person whom the law or a will ap of the subject. The shadow of the tragedy from which the points to succeed thereto, both perish in a common disaster, their deaths occurring in case arose was rendered deeper to some of those- present at the hearing, by the fact that unasccrtainable time relation to each other. This problem was first presented to the a member of the court and one of its officers courts of England in the case of the King both suffered the loss of their parents in a v. Hay (i Wm. Blacks. 640) in the reign of similar disaster at sea, while one of the vic George III. and so novel were the facts to tims of this particular wreck was a classmate English jurisprudence that Lord Mansfield, of the writer. to whom the question was submitted, Mrs. Sophie Rhodes, with her son Eugene, found the strict rules of the common law both being residents of the United States, totally inadequate for its decision, and ac sailed from Bremen, Germany, on the cordingly recommended a compromise in the steamer "Elbe," in response to a cablegram distribution of the estate involved, saying announcing the death of her husband, on the that "there was no legal principle upon twenty-ninth of January, 1895. At half past which he could decide it."1 This compromise five o'clock the following morning, while has since become famous in English law as about due west of The Hague, the ship col "Lord Mansfield's Undecided Case," and it lided with the ship "Crathie," bound from left the question in an unsettled condition in Rotterdam to Scotland, and within twenty England until eighty-seven years later, when minutes thereafter the "Elbe" went down, by the decision of the House of Lords in and <both mother and son, together with Wing v. Angrave (8 H. L. Reps.) the ques many others, perished, t'here (beimg but tion was finally and conclusively set at rest in twenty-one survivors from the whole list of that jurisdiction. passengers and ship's company. A last will While the courts of the several states in and testament of Mrs. Rhodes, dated May this countrv have sought to arrive at a satis 10, 1894, was presented and duly admitted factory determination of the question, and to probate in the Supreme Court of the Dis have apparently found in the solution of trict of Columbia. It contained the follow 1 Taylor i: Diplock, 2 I'hillimore 261, note c. Fearne's ing provisions: Posthumous Works, 38.