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 Latest Important Cases that case it held that such laws, within the meaning of the federal Constitution, had refer ence to criminal punishments, and did not include retrospective laws of a different character. That case has been cited and followed in later cases in this court.

See Kring v. Missouri,

107 U. S. 221, 27 L. ed. 506, 2 Sup. Ct. Rep. 443; Orr v. Gihnon, 183 U. S. 278, 285, 46 L. ed. 196, 200, 22 Sup. Ct. Rep. 213." The Kentucky statute was sustained as imposing, as construed by the highest court of the state, no retrospective penalties or punish ment of a criminal nature. Taxation. Equity cannot Interfere to Determine Validity of Unpaid Taxes —-Bills of Interpleader. Mass. That equity will not interfere to determine the propriety of taxes before they are paid over to the collecting oﬂicials, or to decide whether taxpayers are assessed in the towns or cities in which they have a legal residence, was the holding of the Massachusetts Supreme Judicial Court in Welch v. Boston, 208 Mass.——, decided March 3. This was a bill in equity brought by Francis C. Welch et 01., as executors and trustees of the

estate of the late Quincy A. Shaw. The residue of the estate amounted to about $23,000,000, the cities of Boston and Beverly and the towns of Milton and Brookline each claiming their proportionate share of the taxes. The executors desired to leave the decision as to the proportion in which they should pay to the Court, and expressed their willingness to abide by the result. The Court held that it had no jurisdiction of the bill: — "it is not a case to settle the right to certain property which is brought into court. The claim of each of the defendants is entirely independent

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of that of each of the others. it is not a case in which the plaintiffs are free from interest in the controversy. The plaintiffs ask the court to determine the truth as to certain facts which are in dispute between the parties and upon the existence of which the legal rights of some of the parties, in the performance of their oﬂicial duties, depended when they assumed to perform these duties. The suit cannot be maintained as a bill of interpleader. "It is at least very doubtful whether, apart from considerations to which we have already referred, the bill could be maintained as a bill

in the nature of interpleader. But these consider ations arising from the laws in regard to the raising of money by taxation are conclusive. We have an elaborate statutory system covering this subject, the purpose of which is to assure a prompt collection of revenue for the Govern ment, in its different departments and sub divisions. Remedies are provided for those who are compelled to pay taxes illegally assessed, which are direct and adequate. For this reason it has been decided many times, in this Com monwealth, that equity will not interfere to determine the validity of a tax, but will leave the machinery of the government to move precisely as it was intended to move by the framers of the laws in regard to the assessment of and collection of taxes." The Court held, therefore, that the only remedy available to the executors lay in their paying over the tax and afterward suing to recover it. A similar result was reached in the case of Sears v. Assessors

of Nahant,

208 Mass.——-,

decided on the same date, the court sharply denying the authority of officials of cities and towns to waive their duty of collecting taxes legally assessed pending a test suit as to the validity of the assessment.

IFFERENT persons have different forms of amusement and relaxation. Some might enjoy spending a few quiet evenings revising the Constitution of the

United States."—ALBERT MARTIN KALES, in Illinois Law Review.