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term of imprisonment, and the bill of rights of the islands contains a. provision similar to the Eighth Amendment. The Court de clared that it must give the same interpreta tion to the bill of rights as to the Eighth Amendment and construed the latter as pro hibiting not merely methods of torture long since discarded, but all punishment palpably disproportionate to the offense. The opinion of the court was announced by Mr. Justice McKenna. Perpetuitiea. Statute Authorizing Religious Corporations to Provide for Perpetual Care of Cemetery Lots-Implied Legislative Intent to Abrogate Rule Against Perpetuities. N. Y. In Driscoll v.

Hawlett, decided April 26,

the New York Court of Appeals (see N. Y. Law Jour., May 4), held that the effect of the

provision of the Religious Corporation Law of 1895 of New York State, authorizing such corporations to hold property devised to them in trust and apply the income thereof for the care of cemetery lots, was to abrogate, to that extent, the rule against perpetuities. A testamentary bequest, therefore, to a religious corporation for such a purpose, which became operative while that law was in force, was decided to be valid and not to be affected by the statute against perpetuities. Police Power. Ten- Hour Law for Women Constitutional. Ill. The Supreme Court of Illinois, following the example of the Supreme Court of Oregon and the Supreme Court of the United States in upholding the Oregon ten-hour labor law for women, has sustained the

constitution

ality of a similar statute of the state of Illinois (1909 Hurd, p. 1109).

In the case of

Ritchie et al. v. Wayman et al., decided April 21, the Court (Hand, 1.) reversed its own ruling of ﬁfteen years ago in a case brought by the same party then, and declared : “That while a. man can work for more than ten hours a day without injury to him self, a woman, especially when the burdens

of womanhood are placed upon her, can not. . ..

"And as weakly and sickly women cannot be the mothers of vigorous children, it is of the greatest importance to the public that the state take such measures as may be necessary to protect its women from the con sequences produced by long-continued manual labor in those occupations which tend to break them down physically." (See Chicago Legal News, April 30.)

Statute Fixing Milk Standard Constitu tional-Ignorance of Non-Compliance with Law no Excuse. Mass. The milk standard of Massachusetts was upheld by the Supreme Judicial Court of that state in the case of Commonwealth v. Wheeler et al., decided March 22.

The de

fendants had in their possession to sell, milk containing only 11.65 per cent of solids, the statute requiring 12 per cent. They wanted to show in evidence that they did not know and had no reason to know that the milk contained less than the statutory re— quirement of solids, that the milk was nutri tious, unadulterated, and not injurious to health. This was held immaterial. The court decided that it is within the power of the legislature to fix a standard as the best way of preventing adulteration. Public Health.

See Police Power.

Public Policy. Contract to Provide Aged Woman with Medical Attendance During Her Lifetime not Unlawful. Ill. m-The appellant in an action brought in the Supreme Court of Illinois had contracted with an aged woman patient to furnish her with such medical attendance as should be required during her lifetime for $100,000. payable in ten annual instalments after her death. The Probate Court refusing to allow

the claim, and an appeal being taken to the Supreme Court, the latter, in Zeigler v. Illi

nois Trust & Savings Bank, Exr. (opinion ﬁled April 21, see Chicago Legal News, May 7) held such a contract not against public policy, and said :— "It cannot be seriously contended but that. in order to comply with the terms of this contract and be entitled to receive the bene ﬁts of it, the appellant was bound to give Mrs. McVicker the best treatment within his power and skill and to prolong her life as long as possible. Should he fail to do this, either through neglect, by wilfully treating her in an improper manner or by directly causing her death, appellant would be unable to recover upon the contract. There can be no doubt that a contract to commit murder or any other crime, or a contract to give a

reward to one for the commission of a crime, is void, as against public policy. This con tract does not contemplate the commission of a crime or the doing of anything which is unlawful or contrary to good public morals." Restraint of Trade.

See Contracts.