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 EDITORIAL DEPARTMENT their cases to the general satisfaction as much or more than those of the second tendency, but it is certain that they will not thereby con tribute much to the building up of the law as a system, or to their own lasting fame. The law is a system of principles applicable each to a great many cases or it is as uncertain as the verdict of juries, no one of which is any pre cedent for a succeeding jury. All the judges who are long remembered depend for their rememberance on the legal principles which they have stated in such language as to be a guide to the future." BIOGRAPHY. " Hamilton Fish, Secretary of State," by Alfred Spring. NovemberDecember American Law Review (V. xl, p. 801). BIOGRAPHY (Lincoln). An interesting ad dition to the anecdotes of Lincoln's legal life is made by Duncan T. Mclntyre, entitled "Lincoln and the Matson Slave Case," in the January Illinois Law Review (V. i, p. 386). BIOGRAPHY (Victorian Chancellors). In volume one of "The Victorian Chancellors" (Little, Brown & Co., 1906, 2 vols. @ $4.00) J. B. Atlay, Esq., begins a set of biographical sketches of the occupants of the Woolsack during Queen Victoria's long reign. This first volume deals with Lords Lyndhurst, Brougham, Cottenham, and Truro, and thus covers the early Victorian period. As the author points out, Lord Brougham never held the Great Seal at the hands of Victoria, but his career was so interwoven with the history of the first years of her reign that to omit him would be to emasculate the recital of that history. The work is so well done, with so proper an appreciation of proportion, literary charm, and human interest, that it cannot fail to attract both the laity and the profession, the American as well as the Englishman. The glimpses of history, the anecdotes of great men's chaff, and the vivid descriptions of political crises combine to give the work all the relish of historical fiction without marring its fidelity to truth. The sketch of John Singleton Copley, Baron Lyndhurst, and thrice Lord Chancellor of England is particularly welcome, since it holds to a happy mean between the spiteful

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attitude of Lord Campbell and the rather too laudatory work of Sir Theodore Martin in their respective biographies of Lord Lyndhurst. The wealth of material provided by a life begun in the Province of Massachusetts Bay, May 2i, 1772, and extending to October 12, 1863 is judiciously handled and in such a way as but to properly emphasize the dramatic epochs of that eventful career. Mr. Atlay seems to get under the skin, as it were, and to depict the actual character of his subject as lawyer, politician, statesman, and mem >er of the judiciary. He is particularly happy in his treatment of Lord Lyndhurst's attitude on Catholic Emancipation and Parliamentary Reform and of the immortal charges of politi cal profligacy that followed Copley from the time of his first entrance into Parliament until his death — in singular contrast with the usual English custom which makes it " bad form " to go behind a man's public utterances. In Henry Peter Brougham, first Baron Brougham and Vaux, we find a subject of whom the most able biographer might well despair. His life was one long chain of theatrical incidents; his personality was so striking, so dominant, as to provoke almost limitless discussion among his contemporaries, irreconcilable opinions and statements as to his every motive, act, and characteristic. And of all the interpretations that of Brougham himself is least reliable. Despite these diffi culties the author has produced a well rounded, well balanced, keenly analytic and intensely interesting sketch of this strange person, and one that has all the earmarks of equable, impartial treatment. The chapters devoted to Queen Caroline and the Bill of Pains and Penalties give a graphic picture of an almost unprecedented trial and of the leaders of the bar who appeared for the prosecution and defense. With Lords Cottenham and Truro the situation was reversed and the paucity of authentic material gave Mr. Atlay an even more difficult task, one however that he has satisfactorily performed. With all fairness to their industry and professional acumen he shows that they really owed their highest honors to political exigencies rather than to preeminent fitness. The four lives, as a whole, unite in showing