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 Latest Important Cases Interstate commerce. Business of Corre spondence Schools Interstate Commerce. U. S. The United States Supreme Court held the business of correspondence schools, involving

the solicitation of students in other states by local agents, who are also to collect tuition fees, the systematic intercourse between the corporation and its scholars and agents, and the transportation of books and papers, to be interstate commerce within the meaning of the Constitution, in International

Book Co. v. Pigg, decided April 4.

Text

The Court

(Harlan, J.) said:—

“Referring to the constitutional power of Congress to regulate commerce among the States and with foreign countries, this court said in the Pensacola case just cited (96 U. S. 1) that ‘it is not only the right but the duty of Congress to see to it that intercourse among the states and the transmission of intelligence are not obstructed or unnecessarily incum bered by state legislation.’ This principle has never been modiﬁed by any subsequent decision of this court.” Labor Laws. Labor Unions.

361

“The question of whose conduct it was that led to the abandonment of the husband and the matrimonial domicile by the wife becomes immaterial, since in the Atherton case, as we have observed, the Court refused to pemrit that question to be inquired into in New York for the purpose of impeaching the Kentucky decree. The Kentucky decree having been secured in the state of the matrimonial domicile at the time of the separation upon the ground of desertion by the wife, it fore closed all inquiry in New York as to the offending party. So here, the Virginia decree having been awarded upon evidence to the satisfaction of the courts of the state that the wife wrongfully deserted the husband, full faith and credit would not be accorded by permitting an inquiry into the same ques tion in this District for the purpose of im peaching the foreign decree. We must treat this question as foreclosed by the Virginia decree." Negroes. An Octoroon not a Negro-Louisi ana Concubinage Law Construed. La.

See Police Power. See Contracts.

Marriage and Divorce. Full Faith and Credit Clause—Decree of Divorce Obtained in State of Matrimonial Domicile a Bar to Action for Maintenance Brought Outside the State. D. C. Where the appellant had secured a decree of divorce from his wife in the state of Vir ginia on the ground of desertion, Virginia being the matrimonial domicile of both parties, and the divorced wife, taking up her residence in the District of Columbia, ﬁled a bill against the husband for maintenance in the Supreme Court of the District of Columbia, the Court

of Appeals of the District of Columbia held, in Thompson v. Thompson, decided April 5 (Washington Law Reporter, May 6), that a decree of divorce legally obtained is entitled to the protection of the full faith and credit clause, and is a bar to actions for maintenance brought outside the state. The Court (Van Orsdel, J.) examined the cases of Atherlon v. Atherton, 181 U. S. 155,

and Haddock v. Haddock, 201 U. S. 562, and declared that the facts of the case at bar brought it within the rule of the former of those two decisions rather than the latter, the facts of the Haddock case being "the exact antithesis” of those in the case at bar. The Court said :—

The Supreme Court of Louisiana rendered a decision in April construing the meaning of the word “negro," in the concubinage laws

of the state directed toward the separa tion of the races. The Court sustained the decision of Judge Chrétien in Matter of josephine Lightell, in denying that the Act 87, 1908, could be extended to include an octoroon or any other person having one half or more of Caucasian blood. The Court

(Provosty, I.) said in effect that if the legis lature intended that an octoroon was a negro it should

have said

so, and that

in the

absence of such a deﬁnition in the statute, a person seven-eights white is not aﬂ'ected by its provisions. There was a dissenting opinion, however, holding the word “Negro” to prove the same signiﬁcance as “colored," as a term appli cable to all persons of African descent, mixed

or unmixed. Penal Law. Eighth Amendment—Philip pine Bill of Rights—Cruel and Unusual Pun ishments. U. S. In the case of Paul Weems, decided May 2,

the United States Supreme Court construed the Eighth Amendment to the Constitution,

providing that "cruel and unusual punish ments" shall not be inﬂicted. The appellant, an official in the lighthouse service in the Philippines, had been sentenced to a long