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such ceremony or not, must be certified by the person who performs it, and signed by the parties, and filed in the Probate Court.

The laws of the Territory of Utah which recognize the capacity of illegitimate children to inherit the estate of their father are annulled. A widow in that Territory is endowed with the third part of the lands whereof her husband was seized during marriage and women are deprived of the right of voting.

Congress also passed an act to establish experiment stations in connection with the agricultural colleges established in the several States, and an act to restrict the ownership of real estate in the Territories and in the District of Columbia to American citizens. The latter act makes it unlawful for an alien who has not declared his intentions to become a citizen or a foreign corporation thereafter to acquire or hold real estate, except such as may be acquired by inheritance or in the ordinary course of justice in the collection of debts contracted prior to its passage; but the prohibition does not apply to foreigners whose right to hold real estate is secured by treaties now existing, so long as such treaties are in force.

No corporation, more than twenty per cent. of the stock of which is owned by foreigners, is allowed to acquire real estate; and no corporation, other than railway, canal, or turnpike corporations, is allowed to acquire more than five thousand acres of land; railway, canal, or turnpike corporations may hold lands necessary to the accomplishment of the objects of their creation and such lands as Congress may grant to them, but the act is not to affect lands acquired prior to its passage.

Several of the Northwestern States have adopted the policy of Congress in regard to the acquisition of lands by aliens, and have supplemented Federal legislation by passing laws similar in principle. Colorado, Illinois, Minnesota, Wisconsin, and Nebraska have imitated the example of Congress. The Colorado prohibition applies only to the acquisition of

agricultural, arid, or range lands, and does not affect the holding of any land the assessed value of which does not exceed $5,000.

The prohibition in Nebraska does not apply to lands necessary for the construction and operation of railroads; nor in Minnesota does it apply to actual settlers on farms of more than one hundred and sixty acres; in Wisconsin, however, an alien may hold three hundred and twenty acres of land.

Illinois has added to the severity of congressional legislation by a provision that no lease of any land for the purpose of farming and raising crops thereon, made by an alien landlord, shall contain any provision requiring the tenant to pay taxes, and if anything is received in advance from the tenant in lieu of taxes he may recover it back.

ALABAMA.

This State is only exceeded by North Carolina in the bulk of its legislation. The Acts of North Carolina make a book of eleven hundred pages, while those of Alabama are compressed in a volume of one thousand and thirty-eight pages. This extraordinary legislative activity is due in both States to the vicious system of enacting local and special laws, and to a wonderful development which calls into existence numberless private corporations. As a sample of the intensely local legislation of North Carolina, I mention an act to restrict the catching of fish in Bynum's Mill Pond, in Edgecombe County, in any manner or way, except with hook and line, or by drawing off the water and taking out the large fish for the purpose of improving the fish in the pond.

A partial corrective of the evil in Alabama may be found in the proposed amendment to the Constitution of that State, which is to be submitted to the people at the next general election. It provides "that no bill which does not apply to the whole State (except bills creating and regulating municipal corporations, and bills fixing the time of holding the courts and prescribing rules of procedure therein) shall be

introduced into either house of the Legislature after the twentieth legislative day of the session, nor shall any such bill be considered or passed after the thirty-fifth legislative day of the session; nor shall any bill which applies to the whole State be amended by either house after the twentieth legislative day of the session, so as to confine its operation to a part of the State."

The State of Alabama seems to ignore the maxim, that it is the interest of the Republic to end litigation, if its policy is expressed in the act which requires the Supreme Court in deciding each case, when there is a conflict between its existing opinion and any former ruling in the case, to be governed by what in its opinion at that time is law, without regard to such former ruling of the law by it, but the right of third persons acquired on the faith of the former ruling is not to be defeated or interfered with by or on account of the subsequent ruling.

Women may be appointed notaries public, but not with the power and authority of justices of the peace. Alabama hesitated to intrust the judicial scales to feminine hands. I suppose the legislators thought women's eyes were never blind. The common law as to the effect of marriage on the rights and liabilities of husband and wife has been superseded by an act which declares that all the property of the wife, held by her at the time of her marriage, or which she may in any manner acquire after her marriage, is her separate property and is not subject to the liabilities of her husband; that her earnings are her separate property, also all damages she may be entitled to recover for injuries to her person or property; that the husband is not liable for the ante-nuptial debts of the wife, nor for her post-nuptial contracts or torts; that the wife may sue and be sued as if she were sole; she has capacity to contract with the assent of her husband in writing; she may, with similar consent, recorded in the Probate Court, pursue any trade or business as if she were sole; and to obliterate the last vestige of the oneness of man and

wife, the statute, with revolutionary disregard of the doctrine taught by the year-books, " eadem coro vir et uxor," proceeds to authorize the husband and the wife to contract with each other, but all contracts into which they enter are subject to the rules of law as to contracts between persons standing in confidential relations. The only contract she is forbidden to make is that of suretyship for her husband.

Among other statutes of interest is an act limiting the duration of lien on lands resulting from the registry of a judgment or decree to ten years from the date of registry; also an act which declares void as to third persons having no notice all absolute conveyances as well as all mortgages of real estate to secure debts created at the date thereof unless recorded within thirty days from their date; also an act to authorize the acceptance of a certain class of corporations as surety on official bonds; also an act which requires the court in the cases of larceny, embezzlement, and other like offenses, where the defendant is found guilty, to assess the value of the article stolen or embezzled as part of the costs, and when the costs, including such value, are paid or worked out at hard labor, the County Court is to pay the owner such value out of the fund arising from the proceeds of such labor; also an act for the recusation of judges on account of interest or relationship to the parties by consanguinity or affinity in the fourth degree, or on account of having been of counsel, or of having prepared or signed any instrument the construction or validity of which is involved in the cause; also an act to prevent extortionate charges for the trespassing of cattle on the lands of another; the owner of the cattle by tendering what he considers the amount of damage done can subject the complainant to all costs of suit in case the amount tendered turns out to have been adequate compensation for the damage; also an act which provides that in all contracts for the sale of commercial fertilizers in which an excessive price is put on the article sold, with a stipulation that if paid for on or before a certain date it may be paid in a smaller

sum than the price fixed in the contract, the difference between the excessive price fixed in the contract and the real market value shall be deemed a penalty and only the real market value can be recovered.

Railroad companies are required to provide for the comfort and accommodation of passengers at each station, and to keep a register of the animals injured or killed by their trains at the station nearest to the accident; they are forbidden to employ any person in a position which requires the use or discernment of form or color signals unless he possess a certificate from the State Board of Health of his fitness therefor, in so far as color-blindness and visual powers are concerned; nor can any locomotive engineer be employed unless licensed after examination by a State Board of Examiners, composed of five skilled mechanics appointed by the Governor.

It is made a penal offense to compel a child under eighteen years of age or a woman to labor in a mechanical or manufacturing business more than eight hours a day, or to permit a child under fourteen years of age to work therein longer than eight hours a day, and the employment of children under fifteen years of age in coal or iron mines is prohibited.

The sale of adulterated sugar, lard, molasses, butter, or other article of food, unless branded as such, is punished by fine and imprisonment. This State has adopted a revision and codification of its public statutes, both civil and criminal, which is to go into operation in thirty days after the proclamation of the Governor announcing its publication.

ARKANSAS.

This State has enacted that an assignment for the benefit of creditors may be attacked for fraud by any creditor, and proof of fraud on the part of the assignor shall be sufficient to invalidate the assignment, whether the assignee knew of it or not. An action to enforce a mortgage or deed of trust is barred, if not brought within the period of limitation prescribed for suit on the debt or liability secured. In suits to

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