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 Latest Important Cases question, except the amount of dam ages."

The Court said: — "It has been argued here that the mere fact that any individual defend ant was a member of and contributed money to the treasury of the United

Hatters’ Association made him princi pal of any and all agents who might be employed by its oﬂicers in carrying out

the objects of the Association, and responsible as principals if such agents used illegal methods or caused illegal methods to be used in undertaking to carry out their objects. We cannot

assent to this proposition. . . . Some thing more must be shown, as for instance that with the knowledge of the members

unlawful means had been so frequently used with the express tacit approval of the Association that its agents were warranted in assuming that they might

371

Court of Appeals of the District of Columbia and the Supreme Court of the District erred in treating the con tempt proceedings as a criminal case

and not a civil one. The Court (Lamar, J.) said:—

“This was a proceeding in equity for civil contempt, where the only remedial relief possible was a ﬁne payable to the complainant. The company prayed

‘for such relief as the nature of its case may require,’ and when the main cause was terminated by a settlement of all differences between the parties the com plainant did not require and was not

entitled to any compensation or relief of any other character. The present proceeding necessarily ended with the settlement of the main cause of which

it isapart. . . . The criminal sentences imposed in the civil case therefore should be set aside."

use such unlawful means in the future,

Forest Reserves. Power of Congress that the Association and its members would approve or tolerate such use whenever the end sought to be obtained might best be obtained thereby."

to Establish Without State's Consent— Wilful Trespass — AdministrativePowers —Federal Public Lands. U. S.

Conservation of Natural sources. See Forest Reserves.

gress cannot constitutionally withdraw

Replying to the contention that Con Re

Distinction between Civil

large tracts of land from settlement without the consent of the state where it

and Criminal Oﬁ'ense—Proceedings in

is located, the United States Supreme

Equity for Civil Contempt Make only

Court (Lamar, J.) said in Light v. U. 5., decided May 1 (L. ed. adv. sheets p.

Contempt.

Fines Possible.

U. S.

In Gompers v. Buck's Stove & Range Co.,

L.

ed.

adv.

sheets,

492,

the

United States Supreme Court held on May 15 that Samuel Gompers, John Mitchell and Frank Morrison, president, vice-president and secretary, respec

tively, of the American Federation of Labor, had been erroneously sentenced to jail on a charge of contempt of a

local court. held ﬁnes the be imposed. the United

The Court unanimously only sentences that could The Supreme Court of States found that the

485): “ ‘All the public lands of the nation

are held in trust for the people of the whole country.’ U. S. v. Trinidad Coal 8c Coking Co., 137 U. S. 160, 34 L. ed. 640, 11 Sup. Ct., Rep. 57. And it is not for the courts to say how that trust shall be administered. That is for Congress to

determine. The courts cannot compel it to set aside the lands for settlement, or to suffer them to be used for agri cultural or grazing purposes, nor inter fere when, in the exercise of its discretion,