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 Latest Important Cases Automobiles. a "Carriage."

A Taxicab cannot be called Mass.

A taxicab has been held not a "carriage" within the meaning of the statute, in the case of Goldman v. Commonwealth, recently decided by the Supreme Judicial Court of Massachusetts. The appellant had been arrested and ﬁned for non-payment of fare, but appealed on the ground that chap. 103, sec. 55, of the Revised Laws afforded no protection to owners of automobiles. The Court declared it was certain that the legisla ture, in using the word “carriage," had no thought of a vehicle made up in a large part of complicated machinery and propelled by a powerful engine, whose operation is similar to that of a locomotive on a railroad. Carriers. May not be Required to Connect their Tracks with Grain Elevators——-Police Power. U. S. The Nebraska statute requiring railways to build switches leading to all grain elevators upon their tracks, upon demand, was declared unconstitutional by the Supreme Court of the United States April 4 in Nebraska v. Missouri Paciﬁc Ry. Co. The opinion. which was delivered by Mr. Justice Holmes, was based on the ground that such a requirement exceeded the limits of the police power and invaded the constitutional rights of private property.

See Interstate Commerce, Public Service Corporations. Corporations.

See Interstate Commerce.

Eminent Domain.

See Real Property.

Employer's Liability. Evidence.

See Procedure.

a tax on the capital stock of foreign corpora tions, imposed as a condition precedent to engaging in business within the state, being adjudged an illegal burden on the interstate business of a foreign telegraph company. Mr. Justice Harlan wrote the opinion of the Court, as in the two earlier cases, and as in those cases, the Chief Justice, Mr. Justice Holmes, and Mr. Justice McKenna dissented. Fourteenth Amendment-Equal Protection of the Laws Violated by Tax on Foreign Corporations against which State Tax Laws

Discriminate.

U. S.

The decisions in the Western Union Telegraph and Pullman cases also furnished, in a considerable degree, the authority for the decision of the United States Supreme Court in Southern Railway Co. v. Greene, wherein the proposition was laid down that a foreign railway corporation which has acquired permanent property in a state and has carried on its business within its territory in con formity with its laws, is a "person" within the equal protection of the laws clause of the Fourteenth Amendment, and cannot be subjected, by new state legislation not taxing domestic corporations in the same manner. to an additional franchise tax for the privi

lege of doing business within the state. The opinion was delivered by Mr. Justice Day, and as in the other important interstate commerce cases above referred to, the Chief Justice, Mr. Justice McKenna, and Mr. Justice Holmes dissented. SeeCarriers. Negligence. Evidence of Rules Governing Operation of Cars Admissible-Master and Servant. S. C.

See Negligence, Real Property.

Interstate Oommerco. State Tax on Foreign Corporations Unconstitutional Burden on Interstate Commerce.

U. S.

Similar principles to those involved in the judgments of the United States Supreme Court in Western Union Telegraph Co. v. Kansas (216 U. S. 1, 30 Sup. Ct. Rep. 190,

see 22 Green Bag 192), and in Pullman Co. v. Kansas (30 Sup. Ct. Rep. 232, see 22 Green Bag 250), were applied by the Supreme Court in Ludwig v. Western Union Telegraph Co.,

In McCormick vff'Columbia Electric Street Ry. Co., decided April 8, the Supreme Court of South Carolina declared the rules at companies regarding the conduct of their employees and the operation of their cars to be admissible in evidence, for the purpose of proving negligence in actions for personal injuries. The defendant company had a rule prohibiting its cars from being run at closer intervals than two hundred feet, except at terminals or junctions, and where a motorman whose car had caused the injuries had violated