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 NOTES OF RECENT CASES OF IMPORTANCE FROM THE NATIONAL REPORTER SYSTEM. ^Copies of the pamphlet Reporters containing full reports of any of these decisions may be secured from the West Publishing Company, St. Paul, Minnesota, at 25 cents each. In ordering, the title of the desired case should be given as well as the citation of volume and page of the Reporter in which it is printed.)

ACCIDENT INSURANCE. (CAUSE OF DEATH, BLOOD POISONING FOLLOWING WOUND.) IOWA SUPREME COURT.

In Delaney v. Modern Accident Club, 97 Northwestern Reporter 91, the court holds that death resulting from blood poisoning following a wound received on a finger, is an accidental death within the terms of an accident insurance certificate. A number of authorities are elaborately re viewed, and the court holds that it is imma terial whether the bacilli causing the disease were introduced into the wound at the time it was inflicted and by the instrument inflicting it. or whether they were introduced after wards and from other sources. "A disease brought about as the result of a wound, even though not the necessary or probable result, yet if it is the natural result of the wound and not of an independent cause, is properly attributed to the wound, and death resulting from the disease is a death resulting from the wound, even though the wound was not in its nature mortal or even dangerous. Even though the wound results in disease or death through the negligence of the injured person in failing to take ordinary and reasonable precautions to avoid the consequences, the death is the result of the wound." ALIENS. (CONTRACT LABORERS — MEMBERS OF LEARNED PROFESSION — EXPERT ACCOUNTANTS.) UNITED STATES CIRCUIT COURT, SOUTHERN DISTRICT, NEW YORK.

In re Ellis and In re Charalambis, 124 Federal Reporter 637. Two impor tant holdings were made in these cases on the importation of contract labor. The first is. that the omission, in Act of Congress, March 3, 1903, c. 1012, 32 Stat. 1213 (amend ing and reënacting the previous Immigra-

j tion Laws and repealing conflicting provi sions) of the clause contained in Act of March 3, 1891, c. 551, 26 Stat. 1884, excluding "the class of contract laborers excluded by the Act of Feb. 26, 1885,'' did not amount to a repeal of that provision in the Acts of 1885 and 180.1. This result is reached in view of the recital in the Congressional Record, p. 3205, showing that the House concurred in a Senate amendment omitting this clause, "leaving intact the Contract Labor Laws heretofore enacted and now on the statute ! books." The Act of Feb. 26, 1885, c. 164, 1 23 Stat. 332, forbade the immigration of any alien under contract made previous to im migration to perform labor or service of any kind in the United States : and under this, decision this provision is still operative. The 1 second holding is that an expert accountant I is not a person belonging to any recognized lenrned profession so as to be within the exception contained in Act of March 3, 1903, c. IOI2, §2, 32 Stat. 1214. This holding seems to turn on the incorporation of the word "learned" in the act of that year which had been omitted from previous statutes. Just what constitutes a member of a "learn ed" profession the court does not say. ARCHITECTS. (PUBLICATION OK PLANS— FILING WITH BUILDING DEPARTMENT — Loss OF PROP ERTY RIGHTS.) NEW YORK SUPREME COURT.

In Wright v. Eisle, 83 New York Supple ment 887, the property rights of an architect in plans prepared by him and filed with the building department of the city where the building is to be erected, are considered and held to be thereby lost. The building department had approved of plaintiff's plans, and in consequence he su