332 HARVARD LAW REVIEW. not only that the State was not liable, but that the Legislature never had intended that it should be liable in such cases, and that it was contrary to public policy that the State should be required to pay damages of this kind. Having lost its suit in court, the plaintiff then went to the Legislature, and received from it a special compensation in the shape of a resolve granting the money which the court had said the State ought not to be required to pay. The third branch of State gratuities consists of dispensations of charity, pure and simple, to individuals, from the money contributed in taxes by other individuals. Thus in 1881, ;^50CX) was given to citizens and taxpayers of the town of Westfield for the purpose of rendering them some relief in view of the disastrous floods there.^ And the bad prec- edent was followed in the presentation to citizens of the town of Lee of $3000 in 1886 for the same reason.^ In 1886, $2CX)0 were given to the town of Monroe for the cost of a road ordered to be built by the county commissioners, which was claimed to be " of little benefit to the town but entirely to the benefit of the State by contributing to the business of the Troy and Greenfield R. R. and the Hoosac Tunnel; " and in 1888, 1^2500 were given to the town of Florida for the same reason.^ Two thousand four hundred dollars were presented in 1884 to twelve inhabitants of Gay Head " for their perilous, effective and meri- torious service in the lifeboat, whereby lives of twenty persons were saved from the wreck of the steamer ' City of Columbus.' " * Three thousand dollars were in 1893 given to A. B. and " the family of five men who lost their lives in attempting to rescue the crew of brig 'Aquatic' wrecked on Cuttyhunk," '"" and ^47.20 to the town of Nantucket in 1898, " being the amount expended in caring for the crews " of certain wrecked vessels.^ In 1883, ^4836.51 were presented to a certain contractor for " loss sustained under a contract with the State for work done on the Hoosac Tunnel." So, too, a contractor was presented in 1898 with i^i374 for " loss sustained by reason of an error in a contract for building a public bath house for the State." And in 1887, 1^2500 were given to the owner of a building for loss on account of 1 1881, ch. 46. 2 1886, ch. 66. 8 1886, ch. 35 ; 1888, ch. 80. * 1884, ch. 41. ' 1893, '^^- 36- ® 1898, ch. 22.