was a valid trust for proper purposes. The unincorporated bodies mentioned, although their membership was constantly changing, were sufficiently identified as cestuis, and they were properly represented by prominent members, suing in behalf of themselves and others. The nature of the Archbishop's interest was permitted to be shown by the laws and canons of the church, although some of them ran back for fifteen centuries. Mannix v. Purcell, 19 N. E. Rep. 572 (Ohio).
Willis — Attestation. — In New York, either an attesting witness to a will must see the testator sign his name, or the testator, exhibiting the signature to the witness, must acknowledge it to be his. Consequently an attestation is insufficient, if the will is so folded that the witness cannot see the signature, although the testator acknowledges the instrument to be his last will and testament. In re Mackay's Will, 18 N. E. Rep. 433 (N. Y.).
Willis — Mental Capacity of Testator. — A testator is mentally competent if he have mind enough to understand the nature of the transaction in which he is engaged, and be mentally capable of recollecting the property which he means to dispose of, the objects of his bounty, and the manner in which he wishes to distribute it among them. Kerr v. Lunsford, 8 S. E. Rep. 493 (W. Va.).
REVIEWS.
American Constitutional Law. By J. I. Clark Hare, LL.D. In two volumes. Little, Brown, & Co., Boston, 1889. 8vo. Pages 1,400.
No apology is needed for a new work on constitutional law, for however able the past treatises have been, the subject is one of such constant development that the method of annotation is unsatisfactory. The recent cases are too important to be summarized in a foot-note. The book before us has the additional interest of coming from the pen of Judge Hare, for whatever the learned author of "Contracts" has to say is sure to be suggestive. As far as the substance of the work is concerned, the result is not disappointing. It contains an astonishing mass of material gleaned from every field of constitutional history. The work deserves particular mention for its suggestive, although sometimes disproportioned, treatment of some of the distinctively modern problems. Such is Lecture XIX., on Civil-Service Reform and the Primary System. Every here and there, also, a little note or some side remark opens up a broad field of thought in a manner somewhat diffuse, but, on the whole, invigorating. It can fairly be said that in breadth, in learning, and in suggestiveness the work is a valuable contribution to the subject.
It is to be regretted, however, that the form in which the work is presented is by no means equal to its substance. It seems to suffer from a lack of method, brought about in part, perhaps, from the unwieldy mass of material. The different lectures have no distinctive titles, so that it is sometimes difficult to tell at a glance what the main thread of the lecture is about. The divisions of the subject are not always clearly treated as a whole, although the remarks on individual cases are acute and discriminating. An example of this is the commerce clause, a subject which more than any other seems almost to demand a chronological arrangement to show its development. After a treatment of Gibbons v. Ogden, in which it is hard to see just where
