I RECENT CASES ' 83 after to the date of the decree, to prevent the fiduciary from acquiring unjust gain. Reli, compound interest allowed. Arnold v. Maxwell, 119 N. E. 776 (Mass.). Compound interest may be allowed in order to prevent a fiduciary from ac- quiring unjust gain. Schiefflin v. Steward, i Johns. (N. Y.) 620; Jennison v. Hapgood, 10 Pick. (Mass.) 77. But the law of the case is as handed down in the prior adjudication of the court; i.e., simple interest from the settlement to the bill. Arnold v. Maxwell, 223 Mass. 47, in N. E. 687. And the court now declares that decision to be the law of the case. Compound interest might have been awarded at the outset, but this decision is inconsistent with itself when it announces a former award of simple interest to be the law of the case and then proceeds to allow compoimd interest. The court may have been un- consciously invoking the Massachusetts rule that a decree might bear in- terest. East Tennessee Land Co. v. Leeson, 185 Mass. 4, 69 N. E. 351. See Mass. R. L. c. 177, § 8. However, the decision is still difficult to explain, since imder the Massachusetts rule interest would be computed from the settlement to the bill with interest on that total from the date of the first decree, and not with a rest at the date of the bill. No interest at all would be allowed during the interval between the bill and the first decree. Elections — Election Certificates Binding till directly Over- turned. — Art.r4, Pt. 3, § 17 of the Maine Constitution provides for a refer- endum of any statute passed but not yet in force on petition of ten thousand electors filed with the Secretary of State within ninety days after the recess of the legislature. Each petition must be accompanied by a certificate of the city or town clerk stating that all the signatures on the petition are names of electors on the voting list. Within the ninety days a city clerk who had done such certifying wrote to the Secretary of State, saying that he had not ascertained whether all the petitioners had their names on the voting list. Held, the names of these petitioners should be counted. In re Opinion of the Justices, 103 Atl. 761 (Me.). It is well settled that a certificate drawn in due form by the proper official is final and binding until it is directly, and not collaterally, attacked. In re Rothwell, 44 Mo. App. 215; State v. Kersten, 118 Wis. 287, 95 N. W. 120; Ryan V. Varga, 37 la. 78; Ewing v. Thompson, 43 Pa. St. 372; State v. Churchill, 15 Minn. 455; Warner v. Meyers, 4 Ore. 72; Morgan v. Quackenbush, 22 Barb. (N. Y.) 72; United States v. Arredondo, 6 Pet. (U. S.) 691. Indeed, even the officer issuing the certificate cannot issue a later valid certificate unless defi- nitely allowed a reviewing power by statute. Bowen v. Hixon, 45 Mo. 340; Hadley v. Mayor of Albany, 33 N. Y. 603. In the principal case the city clerk might within the ninety days have made a formal cancellation or amendment in accord with facts upon the certificate and petitions. Until he did so, they remained valid. But to prevent a miscarriage of the intent of the constitu- tional provision the governor or some interested party may attack the certifi- cate directly by quo warranto process. State v. Freeholders of Hudson County, 35 N. J. L. 269; State v. Chosen Freeholders of Camden, 35 N. J. L. 217; People V. Miller, 16 Mich. 56; Atherton v. Sherwood, 15 Minn. 225; State v. Churchill, 15 Minn. 455; Warner v. Meyers, 4 Ore. 72. Or it may be attacked by man- damus where such procedure is allowed. State v. Peacock, 15 Neb. 442, 19 N. W. 685; State v. Stearns, 11 Neb. 104, 7 N. W. 743; Flanders v. Roberts, 182 Mass. 524, 65 N. E. 902. Evidence — Coroner's Verdict — Industrial Boards. — In a proceed- ing before the Illinois Industrial Board to recover compensation under the Workmen's Compensation Act, a coroner's verdict was admitted in evidence to show the circumstances under which the deceased met his death. Held,
