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 Latest Important Cases Biography. Choate. "Rufus Choate." By George Bryan. 17 Virginia Law Register 817 (Mar.). "Any public speaker who can emerge from the test of a stenographic report of extemporaneous remarks in as perfect 'form' as did Mr. Choate from his jury cases must of necessity be endowed with great gifts." Harlan. "A Tribute to Mr. Justice Harlan." By Chief Justice Edward Douglass White. North American Review, v. 195, p. 289 (Mar.). A eulogy pronounced in reply to resolutions passed by the members of the bar of the Supreme Court of the United States and presented by the Attorney-General. "He possessed a reverence for and an implicit faith in our constitutional institutions, a faith which knew no doubt and caused him to believe that the power of adaptability of those institu tions was adequate to meet and provide for any possible condition, however complex or novel. . . . His methods of thought, in disregard of mere subtleties or refined distinctions, led him to the broadest lines of conviction, and as those lines were by him discerned, and differences be tween himself and others became impossible of reconciliation, the warfare of mind with mind was by him carried on, not with adroit fence or

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subtle play of reason, but with a directness and entire disregard of all narrower points of view." "Justice Harlan." By Robert T. McCracken. 60 Univ. of Pa. Law Review 297 (Feb.). "His mind was essentially simple in its work ings, free from delight in subtle distinctions, re sorting rather to direct and vigorous logic. He was prone to follow authority, and was never so well satisfied as when he could succeed in bringing in a given set of facts under the opera tion of some recognized adjudication." Democracy. "The Prospects of AngloSaxon Democracy." By L. T. Hobhouse. At lantic, v. 109, p. 345 (Mar.). "Syndicalism in England is simply a reversion to older methods. . . . Emotional and fitful in its character, the movement breaks out readily into strikes to which the more stable and highlyorganized unions rarely resort. It depends on immediate success, and the conditions this year were favorable to success. ... In particular it cannot withstand seasons of bad trade and slack employment, and the last great movement of the kind, that of 1889 and 1890, crumbled away in the lean years that followed hard upon that crest of industrial prosperity. Nevertheless the revived movement is a real if not a very stable force."

Latest Important Cases Explosives. Sale of Dangerous A rticle Under Assumed Name — A Particular Brand of Stove-Blacking is Naphtha. Mass. According to a decision rendered by the Supreme Court of Massachusetts in Gately v. Taylor et al., the jury may determine a compound of which naphtha is the chief ingredient, to which pigment and adhesive thickening has been applied so that it can be sold as stove blacking, "to remain really and essentially naph tha," notwithstanding the contention of defendants' expert that the article was "an asphalt paint." Consequently, where the particular brand of stove blacking purchased from the defendants had exploded and fatally injured the wife of the plaintiff, it was held that the defendants were liable for damages, under a statute making it a penal offense to sell naphtha under any assumed name and providing a civil

action for any damage resulting from an explosion, independently of any question of negligence. Initiative and Referendum. "Re publican Form of Government" — Con stitutionality of Initiative and Referendum a Political Question — Courts May not Invade Province of Congress. U. S. In Pacific States Telephone fir Tele graph Co. v. Oregon, 223 U. S. 118, 56 L. Ed.—.decided February 19, the Su preme Court of the United States unanimously held that whether the adoption by a state of the initiative and referendum is consistent with a republican form of government is a political question and not within the jurisdiction of the court, and that the duty of enforcing the provision of the Constitution, that the United States shall guarantee to every state a republi can form of government, is imposed