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 Latest Important Cases convict life in a humanely administered prison in which discipline was well maintained. The writer's point of view is directly opposite to that of Lowrie in his recent book on the California prison of San Quentin, and unconsciously does honor to the effectiveness of the newer penal methods. Procedure. See Criminal Procedure. Railway Rates. "Present Problems in Rail way Regulation." By William Z. Ripley. Politi cal Science Quarterly, v. 27, p. 428 (Sept.). "May power to fix minimum rates, so neces sary to an adequate program of control, be consti tutionally delegated by Congress? . . . Surely it seems an anomaly that the Government should ever seek to fix such a lower limit below which compensation may not be had. And yet many cases show that this is absolutely necessary to the end that justice may be done." Social Progress. The Abolition of Pov erty." By Jacob H. Hollander, Professor of Political Economy, Johns Hopkins University. Atlantic, . 110, p. 492 (Oct.). "In the last fifteen years the population of the civilized world, excluding China, has been

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increasing at the rate of about one per cent a year, whereas the average annual increase in the five great cereals, wheat, corn, oats, rye, and barley, has been about 2.5 per cent. In other words, production has increased two and a half times as much as was necessary to keep per capita consumption constant." Taxation. "Recent Tax Reforms Abroad, I," By Prof. E. R. A. Seligman. Political Science Quarterly, v. 27, p. 454 (Sept.). Meeting of significant developments in Great Britain, Germany, and Australia. Workmen's Compensation. "How Ger many Deals with Workmen's Injuries." By Eva E. vom Baur. Political Science Quarterly, v. 27, p. 470 (Sept.). Interesting statistics are presented. If the same interest and sympathy could be instilled into the minds of American as of German em ployers, "we would not have to read that barely one-eighth of the industrial accidents are paid for, and that the best showing has been made by Wisconsin, where fifty per cent of the injured workmen received some compensation, if only for medical purposes."

Latest Important Cases Defamation. Libel per se — Words Imputing Want of Business Credit. Md. The plaintiff in Stannard v. Wilcox & Gibbs Sewing Machine Co. purchased a sewing machine of the defendants, and after paying four months' instalments declined to make further payments and asked for the removal of the machine. The defendants then wrote to the New York cor poration, of which plaintiff was the local agent, reciting the foregoing facts and threatening a civil suit against the plaintiff. On learning of the contents of this letter the plaintiff brought his action to recover damages for an alleged libel, and the demurrer of the defendants was sustained by the Court below. In the Court of Appeals of Maryland the judgment was affirmed (May 10, 1912), the Court (Stockbridge, J.), after reviewing the authorities on communications libelous per se, saying: — "A generalization from all these cases leads to the conclusion that in order for words not ordi narily actionable in themselves to be libelous per se, because affecting the plaintiff in respect to his business, occupation or profession, it is necessary that the words have a reference to him in that capacity. Words which impute to per

sons engaged in business, such as merchants traders and others in occupations where credit, is essential to the successful prosecution of their occupation, nonpayment of debts, want of credit or actions which tend to lessen their credit, are libelous per se, unless they are privileged communications. In this case, Mr. Stannard was not in business on his own account, he was the local manager for a nonresident corporation. It is not alleged or suggested that he had any occasion for the use of credit, or that his credit had been in any way impaired or affected." (Washington Law Reporter, Sept. 20.) Election Laws. — Nomination Certificates of Independent Candidates — Unreasonable and Discriminating Statute Requirements Governing Number of Signers — Provision of Levy Law Unconstitutional. N. Y. By a decision handed down in New York State Sept. 5 by Supreme Court Justice A. S. Tompkins the provision of the Levy election law making 1,500 signatures necessary in an independent nomination petition for county officers and 800 signatures for Assemblyman was declared uncon stitutional and void. Justice Tompkins in his opinion concluded that the present law was un-