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 Latest Important Cases dren and herself, with a provision al lowing the property to be transferred to them upon her death. The Court (Lamar, J.) said: — "There is no natural right to create artificial and technical estates with limi tations over, nor has the remainderman any more right to succeed to the posses sion of property under such deeds than legatees and devisees under a will. The privilege of acquiring property by such an instrument is as much dependent upon the law as that of acquiring prop erty by inheritance, and transfers by deed to take effect at death have fre quently been classed with death duties, legacy and inheritance taxes. . . . "The Fourteenth Amendment does not diminish the taxing power of the state, but only requires that in its exercise the citizen must be afforded an oppor tunity to be heard on all questions of liability and value protection. It does not deprive the state of the power to select the subjects of taxation." Literary Property. Copies of Pri vate Letters — Injunction to Restrain Use for Advertising Purposes. Mass. C. F. Libbie & Co. advertised for sale copies of private letters written by Mary Baker G. Eddy to her cousin about 1876, and the executor of Mrs. Eddy's estate applied for an injunction restraining the use of the letters for advertising or other purposes. In the first decision rendered in Massa chusetts regarding proprietary rights in ordinary private letters, the Massa chusetts Supreme Judicial Court (Baker v. C. F. Libbie & Co.) held that no narrow exceptions could materially affect the general rule that an author has a pro prietary right in his letters which will be protected by law. This right involves a right of the author to copy or to secure copies, as otherwise his right of publica

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tion might be lost. An injunction was therefore granted. Railway Rates. Unjust Discrim ination in Freight Charges — Order by Interstate Commerce Commission Prere quisite to an Action. U.S. In Robinson v. Baltimore & Ohio R. R. Co., decided by the United States Su preme Court in an opinion filed Jan. 9, the Court affirmed a judgment of the Supreme Court of Appeals of West Vir ginia, and held that the plaintiff was denied no right by the dismissal of an action against the railroad to recover a difference of fifty cents a ton between the freight paid on coal loaded into its cars from wagons and that which would have been paid had it been loaded from the tipple. The Court said that the interstate commerce act contemplated an investi gation and order by the designated tri bunal, the Interstate Commerce Com mission, as a prerequisite to the right to seek reparation in the courts because of exactions under an established schedule alleged to be violative of the prescribed standards. A different procedure "would be in derogation of the power expressly delegated to the Commission, and would be destructive of the uniformity and equality which the act was designed to secure." Railway Rates. Findings of Inter state Commerce Commission Prima Facie True — Sufficiency of Substantial Evi dence to Sustain an Order. U. S. In Interstate Commerce Commission v. Union Pacific, Northern Pacific and Great Northern Railways, October term, 1911, nos. 151, 152 and 153, the Supreme Court held in an opinion filed Jan. 9, that, as the Interstate Commerce Act makes the findings of the Commission prima facie correct, the courts, on a bill to enjoin the enforcement of an order,