124 HARVARD LAW REVIEW. There is, naturally, a limit in reason as to what carriers are thus bound to transport for such travellers as baggage. Of course it is true, as the St. Louis Appellate Court suggests, that " mere utility or convenience at the end of the journey is not sufficient." The articles must be connected with the purpose of the journey. Then, too, carriers are obliged to carry only such articles as are generally used by persons of this class of travellers, and only in such quanti- ties as are reasonable. Thus a father of a family may not insist on the carriers transporting for him a seventy-eight pound spring horse, forty-four inches in length, which he was taking home with him ; ^ nor may a musician insist on carrying a pianoforte or an organ, nor a student a whole library, nor a mechanic the tools and machinery of a machine-shop^ nor an actor the paraphernalia of a theatre.^ Considering, then, the status of the bicyclist in the light of all these decisions, let us see how the case stands. It must be borne in mind that the bicyclist patronizes almost exclusively the "local trains, or, at most, " local expresses." These trains, although they almost always have a baggage car attached, usually handle very little baggage, so that on a summer's day as the bicyclists stream out from, or back to, town they will be the only ones who will take advantage of the baggage car. It should also be remembered that it is generally on a Sunday or holiday that bicyclists make use of trains, and it is on just such days that the least demand is made upon their baggage facilities by the travelling public at large. Looking at the question from these two points of view, we find that we have, first, the local carrier, a short journey, and a slow- moving train. In this combination we have the train, already in- cluding a suitable baggage car which would otherwise be but little patronized, moving at such a rate and for such a distance that no special attention need be paid to the packing of bicycles in the car. But even if this were not so, would it be asking too much of our modern railway carriers to supply a special car for the transporta- tion of bicycles when we consider how many extra dollars they put into the railroad companies' pockets? Look any holiday at the crowds who flock to the railway stations with their bicycles to be transported beyond the city limits so as to enjoy a day of country 1 Hudston V. Midland Ry. Co., L. R. 4 Q. B. 366. 2 Merrill v. Grinnell, 30 N. Y. 594, 619. 8 Oakes v. N. Pac. R. R. Co., 20 Oregon, 392.
