REVIEWS, 135 Newman was not a purchaser for value, and therefore his prior notice to the holder of the fund did not entitle him to priority. The Elmbank, 72 Fed, Rep. 610. It seems clear on principle that a creditor who takes a thing merely as security for a pre-existing debt gives no value and surrenders no right against his debtor in ex- change for the new security given, and therefore that he is not a purchaser for value. Thus, one who takes personal property as security for a pre-existing debt, takes it sub- ject to equities attached to it in the hands of the debtor. Goodzvin v. Massachusetts Loan Co., 152 Mass. 189, 199; Savings Bankv. Bates, 120 U. S. 556. It is true that, by the prevalent view, one who takes negotiable paper as security for a pre-existing debt takes it free of all equities; Railroad Co. v. Bank, 102 U. S. 14; but it seems clear that the cases taking this view must be supported, not on the ground that the holder is a purchaser for value, but on the ground that he has taken negotiable paper — a thing which in many respects is treated as money — in the course of a business transaction, and that he may therefore hold it free of all equities. REVIEWS. Select Cases from the Coroners' Rolls, A. D. 1265-1413, with a Brief Account of the History of the Office of Coroner. Edited for the Selden Society, by Charles Gross, Ph.D., Assistant Professor of History, Harvard University. London, 1896. The greatest importance of these rolls is historical and chiefly consti- tutional; and Professor Gross has done well in confining himself^ in his excellent and scholarly introduction, to the constitutional position of the coroner, as shown by these rolls and other early authorities. There seems to have been no very close parallel elsewhere to this officer. The English coroner is a curious link between Crown and people. Elected by the people of the county or other local division, the only elective official in the county courts, coming in every case of accidental death and in many others into close relations with the people, he was essentially a popular officer, a product and a proof of local self-government ; on the other hand, he was the direct means of accounting to the central govern- ment for affairs of every-day Hfe in which it was interested, especially by overseeing the operation of the hue and cry, and by securing for the Crown its deodands and similar rights ; and was a check for the King upon the sheriff, though the latter was appointed by the King. No other European nation combined a strong central power with local self-govern- ment ; and it is therefore not surprising that such an officer was nowhere else found. Professor Gross brings out clearly this peculiar position of the coroner ; he speaks well also of the "four neighboring vills," which seem to have persisted until lately, if indeed they do not still form an administrative group. The Introduction is in fact a valuable essay in English consti- tutional history. These rolls have in large measure a quality peculiar to all the English legal rolls ; they are a remarkable witness of the common life of the English people in the Middle Ages. No other nation possesses such material for the history of its people. One cannot but be surprised, in reading these rolls, at the number of small children who fell into ditches or wells, or pots of boiling water, or were buried by falling sand-banks ; and one may well marvel to find that a three-year old boy "feh into a pan full of milk, and thus was drowned by misadventure" (p. 50). The state of the prisons is vividly set forth in a series of presentments in the cases of seven men who were found to have died in the prison of the castle 18
