I88 HARVARD LAW REVIEW. The Massachusetts doctrine that stock dividends never go to the life tenant as income has been adopted in the United States Supreme Court. Gibbons v. Mahouy 136 U. S. 549. The English decisions on the right to stock dividends as between life tenant and remainderman are in a very unsatisfactory condition. The Pennsylvania doctrine is approved in the more recent text-books. I Morawetz, Private Corporations, § 468 ; I Cook, Stock and Stockholders, § 554. Equity — Bigamous Marriage — Fraud of Plaintiff. — Complainant, con- cealing the fact that he was already married, induced defendant to marry him. He afterwards filed his bill inequity, asking that his marriage with defendant be declared a nullity. Held, complainant's fraudulent conduct in procuring the bigamous marriage precluded him from relief in equity. Rooney v. Rooney, 342 Atl. Rep. 682 (N. J.). The Court of Chancery in England did not take jurisdiction of a bill to have a marriage declared a nullity ; such a suit fell within the jurisdiction of the Ecclesiasti- cal Court. 2 Kent's Com., 14th ed., *76. In the Ecclesiastical Court a decree of nullity was pronounced at the instance of a plaintiff in the same situation as the complainant in the principal case. Miles v. Chilton, i Rob. Ecc. 684. This precedent was followed in a case in the Probate and Divorce Division of the English court. Andrews v, Ross, 14 P. D. 15. In the absence of Ecclesiastical Courts in this country, equity has taken jurisdiction of suits to have a marriage declared a nullity. Wightman v. Wigktman, 4 Johns. Ch. 343, at p. 346. But to take jurisdiction of a bill to declare a bigamous marriage a nullity, when the complainant had knowingly procured the marriage, would do violence to one of the fundamental principles of equity. Bishop, Mar., Div. and Sep., § 722, states the law as contra to the decision in the principal case, but the American authorities cited by him do not sustain his statement. In accord with the principal case, Teft v. Teft, 35 Ind. 44. Mortgages — Liability of Grantee of Mortgaged Premises. — A^^/^/ (Dun- bar, J., dissenting), that a mortgagee may enforce the liability of a grantee of the mortgaged premises oh his assumption of the mortgage debt. Solicitors' Loan and Trust Co. V. Robins, 45 Pac. Rep. 39 (Wash.). See Notes. Partnership — Statute of Uses — Trust Deed to Use of Firm. — A statute provided that a conveyance in trust to the use of "any other person or persons or of any body politic " should vest the title in fee in the cestui que tise. Held, that a deed conveying land in trust for the use of a firm, the firm being designated by the firm name, vested no legal title under the statute in the partnership firm or any of its members. Silverman v. Keistufek, 44 N. E. Rep. 430 (111.). A partnership as such cannot hold the legal title to land (Parsons on Partnership, 4th ed., § 265, note i); but there seem to be three views as to what effect a deed of land to a partnership has in conveying a legal title to the members of the firm. One view is, as shown by the principal case, that no one takes any legal estate. Percifull v. Piatt, 36 Ark. 456. Another is in effect that any partner or partners whose names appeared in the firm name hold the land in trust for themselves and the other partners. Moreau v. Saffarans, 3 Sneed, 599; Winter v. Stock, 29 Cal. 407. The last view is that all the partners take the land as joint tenants or tenants in common. Maughan v. Sharfe, 34 L. J. C. P. 19 ; Sherry v. Oilman, 55 Wis. 324 ; Powers v. Robinson, 90 Ala, 225. The last view seems preferable in theory. All the partners must join in suit upon a covenant in a deed to a partnership {Moller v. Lambert, 2 Camp. 548 ; Gates v. Graham., 12 Wend. 53; Brown v. Bostian, 6 Jones (N. C), i) ; and if this is so it would seem that all the parties ought to be grantees as they are covenantees. The only objection to such a view is that it might lead to confusion in the examination of titles. Persons — Married Women — Action for Seduction. — The plaintiff was seduced by the defendant, subsequently married him, and afterward obtained a divorce on the ground that the marriage was obtained through fraud. She then brought suit against the defendant under a statute allowing "an unmarried female to prosecute as plaintiff an action for her own seduction." Another statute provided, in substance, that a married woman may bring an action as if sole for injuries to her person or character. Held, that unless the divorce amounted to a decree annulling the marriage, the plaintiff could not recover. Henneger v. Lomas, 44 N. E. Rep. 462 (Ind.). The court put their decision on the ground that the statute permitting married women to sue as if sole, did not do away with the common law rule that any action a single woman may have had against her husband before marriage is lost by such marriage, and does not revive after divorce. This seems correct, and the cases cited sustain the decision. A narrower ground would have been to say that the legislature could not have intended the action for seduction to survive marriage with the seducer,
