$62 HARVARD LAW REVIEW. Requirements for Admission to the Columbia Law School. — It is with considerable satisfaction that we note the change which has been made in the requirements for admission to the law school of Columbia University. From and after the term year beginning 1903-4 none will be admitted who has not received a Bachelor's degree from an approved col- lege ; and now the law school of Columbia takes its stand beside the law school of Harvard as an essentially graduate department. This change is not to be looked upon as a mere matter of form, nor is it open to the charge of Philistinism. It simply amounts to a recognition of what is becoming the logical development of a university, — a college leading to a number of co-ordinate graduate departments. The fact that the law is of sufficient dignity to be entitled to graduate rather than undergraduate work cannot admit of question. In making this change Harvard and Columbia do not condemn as having no place in the community the schools which, teach law to all comers ; that question is for them irrelevant — the rele- vant question is, what place the law must occupy in the university. As the university develops, a neutral department is becoming impossible ; the law department must take a step, either backward among the under- graduates or forward among the graduates ; it cannot invoke the fiction of law and remain " in tiubibus " or " in gremio legist At Harvard and Columbia the time has come in which some step had to be taken, and no one can say that the choice has not been wisely made. With this change it is obvious that a change has come over the signifi- cance of the degree conferred by these law schools. The class which graduates this year from our law school and the first class to graduate under the new regime at Columbia will for the first time in their respec- tive schools present themselves as candidates for a graduate degree, — a degree which among foreign universities would rank as a doctor's degree. The form of words by which that degree is known may remain unchanged ; but it is a matter for serious consideration whether the development of the university, which is in substance co-ordinatiug the graduate depart- ments, does not require that the forms of the degrees conferred by these graduate departments be also co-ordinated, and that the degree conferred by the law department take its formal stand beside the degrees of the medical and graduate schools. The essential fact, at all events, has been accomplished ; the change in substance is already made. Mere Words as Provocation. — An intentional homicide, if with rea- sonable provocation, is manslaughter, not murder — that distinction remains in nearly all the modern statutes — but the question of provo- cation has always been a troublesome question of fact for a jury. In the older law the judges constantly limited that difficulty, and sought con- sistency in verdicts by laying- down collateral rules in regard to it. If there was " cooling time," there was no provocation ; " mere words " were not provocation. Such rules of thumb received judicial recognition. Lord Morlfs Case, Kel. i, 53, then passed current in the cases and text-books. But changes in public opinion toward the criminal law have affected these two collateral rules as to provocation, — the first, with the phrase " cooling time," has fallen into disuse, the second is constantly questioned. In a recent case. State v. Grugin, 47 S. W. Rep. 1058, the Supreme Court of Missouri held that a charge that words could not be considered provocation was wrong. In that case it appeared that the
