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 The Legal World Harlan, "has touched as deeply the life of the bar or exerted as strong an influence on the profession of the law in this state as he whom we mourn. More than half of its present membership, including eight of the judges of this court, have been numbered among his pupils, have profited by his in struction and have been stimulated to a higher appreciation of the importance and dignity of their calling."

Election Ifesults The New York election is notable on account of the election of former Supreme Court Justice William J. Gaynor as Mayor. Justice Gaynor, who resigned his seat in the Appellate Division Oct. 14, had accepted the nomina tion from Tammany with the statement that he did not see why he should not accept a nomination from any source from which it might be offered. He was fought bitterly by the earnest opponents of Tammany, but succeeded in polling a plurality of 73,000 votes in New York. The Fusion forces, however, secured a complete victory over Tammany Hall in other respects, electing an anti-Tammany Board of Estimate. William T. Jerome had retired from the District Attorney contest early in the campaign, and Charles S. Whitman, the Fusion candidate, was elected by a plurality of 10,000. Justice Charles H. Truax, after losing the indorsement of the Republican organization and being earnestly supported by the New York City Bar Association, failed of re-election to the Supreme Court on the Democratic ticket. In the fifth judicial district, Supreme Court Justice William E. Scripture, Repub lican, was defeated by Edgar S. K. Merrill, Democrat, after the State Bar Association, through its Judiciary Committee, had gone on record against his re-election. This defeat vindicated the principle that the bench must keep out of politics. In Philadelphia the reform candidate for District Attorney, D. Clarence Gibboney, was beaten by Samuel P. Rotan, Republican, who was re-elected by a plurality of 43,000. The Democratic party had refrained from indorsing Gibboney, although he headed its ticket. In San Francisco municipal reform may have received a setback by the defeat of Francis J. Heney for District Attorney. "Business interests" are represented to have been tired out by the graft prosecutions, and Heney was beginning to reach the men higher up. Charles Fickert, Republican and Union Labor nominee, was elected in his place, together with a Union Labor mayor. Negro disfranchisement in Maryland was defeated by a majority of between twelve and fourteen thousand votes. The proposed Straus amendment to the constitution had been drafted with care to avoid a clear violation of the Fifteenth Amendment. Lawyers organized both an Amendment

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League to work for it and an Anti-Amend ment League to oppose. If adopted it would have given power into the hands of the Gorman machine. Some of the opposition vote was due to the fears of foreign-born citizens ignorant of the English language that they, as well as negroes, would lose the franchise. The Lawyers' Anti-Amend ment League, with George Whitelock as president, conducted a most vigorous cam paign on nonpartisan lines. In Boston District Attorney Arthur D. Hill, whose term of office had been marked by striking efficiency in clearing up the formidable arrears bequeathed him by his fredecessors, was defeated by Frank N. elletier, the Democratic candidate. The Democrats of Rhode Island made a stubborn fight for the election of James A. Williams, as Attorney-General, and he had conducted a sensational campaign on the issue of proper enforcement of the laws. The Republican state ticket, however, was elected. Miscellaneous For the first time in California a woman was sworn in to serve as a juror, October 19, in the Superior Court of Los Angeles county. The law department of Tulane University was honored by admission to membership in the Association of American Law Schools at the ninth annual meeting of the body, held in early September at Detroit. Professor George P. Costigan, Jr., has succeeded Professor Roscoe Pound as editor of the Illinois Law Review, published at Northwestern University, Professor Pound having joined the faculty of Chicago Univer sity Law School. Professor Costigan has recently come to Northwestern University from the University of Nebraska College of Law. "When you visit a lawyer to ask about a certain point of law," said Professor Samuel Williston before the American Institute of Banking, October 12, "and upon learning your business he tells you how busy he is, and asks you to call next day, be sure that he will spend those intervening twenty-four hours in diligent study to prepare for your second reception." President Benjamin Ide Wheeler of the University of California, speaking at the University of Berlin October 30 in the presence of the Kaiser, said that he was convinced from personal acquaintance with William J. Bryan, that Mr. Bryan would have been conservative if he had been elected President, but if he had not proved conservative he would have been bound hand and foot and gagged. Ex-President Roosevelt he described as conservative in his innermost impulses.