320 HARVARD LAW REVIEW. lived to the end of the year, but a further salary or grant to the administratrix of the estate of a certain ofhcial who died towards the end of 1893, of the sum of ^625, " being three months' salary from the date of his death." ^ Nor has the Legislature confined its generosity to cases of death. It has made direct gifts of the money from the public treasury to living persons. It has given to a clerk in the office of Province Laws Commission her " loss of pay while disabled by sickness brought on by overwork." ^ A most flagrant case is one of a grant to a clerk in the office of the Tax Commissioner who resigned from ill health, "in recognition of his long and faithful service ^1000."^ And it has several times made grants of permission to clerks in departments at the State House who resigned from illness or inca- pacity, to be kept upon the pay roll for successive years, or of their salary to the end of the year.* These last cases of payments made to living persons are simply the indirect establishment by the Legislature of a civil pension list without the passage of any statute. But the Legislature has not stopped at this point in* making presents of the public moneys to individuals. In 1888, apparently relatives of city officials began to see how easily State employees were acquiring presents from the State, and to ask themselves why a State employee should be more entitled to unearned salaries than a city servant. From 1872 to 1888 there is no record of authority being granted by the Legislature to cities to pay to city officials the balance of salaries to which they would have been entitled if they had lived to the end of the year. In 1888 the Legislature began this practice through special statutes, at first giving cities authority to pay such balances of salary only to high officials, and gradually broadening out until, in 1897, relatives of employees in the Street Department, and of policemen, secured these gratuities from the city by kindness of the Legislature. To show the increase of this quasi-pension legislation, in 1888 the Legislature granted the city of Boston right to pay the balance of his salary to the widow of the principal assessor. In 1889 there was one such grant; in 1890, none; in 1891, two; in 1892, one; in 1893, three, one of them being to the orphan sisters of a pro- bation officer; in 1894, three; in 1895, two; in 1896, one; in 1897, 1 1894, ch. 25. 2 1889, ch. 98 ($450). 8 1896, ch. 116.
- 1886, ch. 4 ($1200); 1890, ch. 115 ($1100) ; 1896, ch. 105 {$600) ; 1897, ch. 38 ($600) ;
1889, ch. 53 ($1591 40); 1891, ch. 6 (1456-99) >• 1894, ch. 93 ($1000).
