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 Latest Important Cases Conflict of Laws. Domicil in Foreign Country where Americans are Subject to Laws of their Own Land-—Succession. Maine. Henry Cunningham abandoned his domicil of origin in Waldo, Me., and made his home, established his business, and had his head quarters, from 1869 until the time of his death thirty-six years later, in Shanghai, China. The problem in blather v. Cunningham, 74 Atlantic Reporter 809, was, Can an American under any circumstances, acquire, as a matter of law, a domicil in the province of Shanghai. a ‘place where, by treaty, American law is substituted for Chinese local laws? Counsel contended that the term domicil necessarily implies subjection and obedience to the local laws of the domicil, and that this cannot be said to be true of a residence in Shanghai,

because its laws governing American citizens are extended by treaty instead of edict. The Supreme Judicial Court of Maine holds that as the ownership of the soil controls the establishment of all local laws, and with

out the consent of the sovereign no extra territorial law can be enacted within an independent jurisdiction, or extended to it, the American law became the local law when

the Emperor of China permitted Congress to extend it by treaty; that the fundamental idea. of domicil does not depend upon any distinction with respect to the source of the law; that Chinese domicil gives a decedent's estate a ﬁxed place of abode, and subjects it to the law governing the locality, and, whether American law or Chinese law, it is,

nevertheless, the law of the place, as to American citizens. After a lengthy but well reasoned and interesting opinion, the con clusion of the court is that Cunningham acquired a domicil of choice in Shanghai. Contempt. Conspiracy to Obstruct Ad ministration of Bankrupt’s Estate-Conceal ment of Assets. U. S. Upon examination before a referee in bankruptcy, the original testimony of a witness, a brother-indaw of the bankrupt and unsuccessful in business, that he loaned

$900 shortly after the bankruptcy to his niece, the bankrupt’s daughter, a girl of not more than nineteen years of age, in cash, to open a small store, was deliberately retracted

at the same examination in the presence of the referee, and in answer to his questions;

and on the following day, after evident

pressure exerted on him during the adjoum~ ment to protect his relatives, such witness proceeded to retract his retraction of the day before, producing two checks purporting to show the payment, although he had never referred to that mode of payment previously. It was held in Matter of Bronstein (D. C., N.

Y.), 24 Am. B. R. 524, that the inherent improbability of the ﬁrst story, the con science-stricken demeanor of the witness at his ﬁrst retraction, and the pitiable ex hibition which he made before the referee

on his second retraction, were convincing evidence of a conspiracy to obstruct the administration of the Bankruptcy Act, and his conduct was punishable as a contempt of court. Husband and wife. Foreign Contracts Enforceable in Country of the Forum When Not Against Public Policy—Negotiable In struments. Wis. A note signed by a married woman as accommodation

maker

for

her

husband,

which is valid in the place where made, is held in International Harvester Co. v. Mc

Adam (Wis.) 26 L.R.A.(N.S.) 774, to be enforceable against her in the courts of another state, although if made in the latter state it would have been void,-—especially where the legislative policy of the forum negatives the idea that the granting to a married woman of full rights to contract involves anything inherently bad, since it is held that foreign contracts, to be unenforce able in the country of the forum, must be injurious to the public welfare in the judg ment of the courts thereof, or must have been prohibited by its legislature as per nicious. Juries. juror Individually Responsible for Determination of Questions Submitted-— No Duty to ll/Iake His Cojurors’ Opinion His Own. N. Y.

In People v. Faber, decided by the New York Court of Appeals Oct. 4, judgment of conviction of murder in the ﬁrst degree was reversed on the ground of misdirection of the jury. The trial court refused to give the