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that it was hers and that she must pay the premiums on it which she did. The husband killed the wife and afterwards com mitted suicide. It was first held that the parol assignment of the policy to the wife vested in her the contingent interest remain ing in the husband. The important question then arose, whether the husband, having murdered the wife, could take her chose in action by virtue of the jus mariti. After an elaborate review of the authorities, the court holds that he could not. It concedes that the case of Riggs v. Palmer, 115 N. Y. 506, 22 North eastern Reporter 188, 5 L. R. A. 240, 12 Am. St. Rep. 819, in which it was held that the general laws for the devolution of prop erty by will or descent did not operate in favor of a murderer whether he claimed as devisee, legatee or heir-at-law, has been overruled by the later cases of Owens v. Owens, loo N. C. 240, 6 Southeastern Re porter 794; Deem г: Milliken, 6 Ohio Cir. Ct. R. 357m, affirmed in 53 Ohio St. 668, 44 Northeastern Reporter 1134; Shellenberger v. Ransom, 41 Neb. 631, 59 Northwestern Reporte'r 935, 25 L. R. A. 564; Carpenter's Estate, 170 Pa. 203, 32 Atlantic Reporter 637, 29 L. R. A. 145, 50 Am. St. Rep. 765. The court relies on the case of Burt v. Union Central Life Ins. Co., 187 U. S. 362, 23 Supreme Court Reporter 139, 47 L. Ed. 216, in which it is held that the assignees of a life policy could not recover where the insured was hung for murder. It says: "It is true in the present case that the insurance company made no contest, but. conceding its liability, paid over the proceeds of the policy, and they await the determination of this suit. But can it be successfully contended that a claim resting upon a felonious act which might have been resisted by the insurance company has acquired more virtue when it is now asserted by the representative of the murderer to the proceeds of the policy? Can those who represent the husband, who first by the felonious destruction of the life of his wife, and then as a fclo de se has acceler ated the maturity of the policy, take the fruits of his crime under the doctrine of

jure mariti?" Cleaver v. Mutual Reserve Fund Life Assn., L. R. i Q. B. Div. 147, in which the assignee of Mrs. Maybrick sought to recover on a policy on the life of Maybrick and in which the company successfully resisted the suit on account of Maybrick's death at the hands of his wife, is also relied on. The provision of the Tennessee constitu tion (article I, section 12) that no conviction shall work forfeiture of an estate, as well as that of the Federal constitution (article I, sections 9 and 10) prohibiting bills of at tainder, are held not to apply, since the pro ceeds of the policy never became a portion of the husband's estate. It is finally held that a refusal to permit a husband who murd ered his wife to take the proceeds of a Hie policy which belonged to her, does not escheat the property to the State, but the title passes to her administrator.

ILLEGAL CONTRACT. (SALE OF COUNTERFEIT MONEY.) • COURT OF APPEALS OF KENTUCKY.

In the case of Chapman v. Haley, 80 Southwestern Reporter 190, action was brought to recover $300 paid to defendant to be invested, as the plaintiff testified in $3,000 worth of "good money." Plaintiff testified that the defendant told him that he was a member of the firm in Cincinnati that had this money, and that he could get $3000 for his $300. "He showed me some new bills, one, two and a twenty, and I think a five and a ten, and he had plenty others, ap parently. The money I was to get was to be just like those he showed me, silver certifi cates, and not counterfeit. He told me to sit down here on the walls of the waterworks, and he would step right across the street and get it and be back in twenty minutes, and he never returned." The plaintiff pro tested that he did not intend to purchase counterfeit money, but that the defendant had told him that it was good money, and said that "there was one one trouble about it, and that when deposited in a bank two numbers running of the same date might be