574 HARVARD LAW REVIEW for the specified cotton. The exchange house surrendered the bill of lading to the drawee bank and obtained its acceptance. The bill of lading was forged. The acceptor paid the ultimate holder of the draft, and debited the buyer of the cotton. Held, the buyer can not recover the amount of the draft from the exchange house. Guaranty Trust Co. v. Hannay &* Co., [1918] 2 K. B. 623 (C. A.). See Notes, page 560. Carriers — Bills of Lading — Forgery of an Interstate Bill of Lading as a Federal Crime. — Defendant was indicted for forging an inter- state biU of lading, an act made criminal by section 41 of the Pomerene Act of 1916. Held, that as such a bill is void, it does not affect interstate com- merce, and hence section 41 is unconstitutional. United States v. Ferger, So. Dist. Ohio, October, 1918. For a discussion of this case, see Notes, page 557, Conflict of Laws — Admiralty — Maritime Lien — Foreign Law. — Two foreign vessels collided in an Algerian port. Thereupon the master of one of the vessels brought an action in personam in the Algerian court against the master of the other. No maritime lien was given by the local law, but an at- tachment of the vessel, there known as a "protective seizure," followed. Upon giving a letter of indemnity the vessel was released and then came to the United States where she was libeled by the plaintiff in the foreign action which had not proceeded to trial or judgment, but was still pending. Held, that the libellant had a maritime lien under the general maritime law of the United States, enforceable by a proceeding in rem. The Kongsli, 252 Fed. 267 (Dist. Ct., Dist. Me.). As a result of the collision the lex loci gave a cause of action, but did not create a maritime lien. In such a case admiralty may take jurisdiction be- tween foreigners to enforce a maritime lien, given by the general maritime law, even though none was given where the cause of action arose. The Kaiser Wilhelm II, 230 Fed. 717. See The Maggie Hammond, 9 Wall. (U. S.) 435, 450, 452. If jurisdiction depends on a maritime lien, it is difficult to see how the court, in the principal case, had jurisdiction, as the lex loci of the collision did not give such a lien. However, there being a cause of action, and the vessel being within the jurisdiction of the court, it seems that the court could give a maritime hen, recognized by its law, as a means of enforcing the cause of action, one of the remedies of its judicial proceeding. See Marsden, Col- lisions at Sea, 6 ed., 198. And as the jurisdiction was in rem, the pendency of the action in personam in the foreign country woiild not be a bar to the present action. The Kalorma, 10 Wall. (U. S.) 204; The Bold Buccleugh, 7 Moore (Privy Council), 267. Conflict of Laws — Divorce — Remarriage Within Prohibited Time — Property Rights. — A statute in Washington prohibits remarriage by either party within six months of a decree of divorce. (19x5, Rem. Code, 419, § 992.) The plaintiff and her husband were divorced in Washington. Two months later, the plaintiff, in company with the defendant, a resident of Washington, went to Canada where the two were married. They imme- diately returned to their domicile in Washington believing in good faith that the marriage was valid. The plaintiff brings suit for annulment and for a division of the property acquired subsequent to the marriage. Held, the marriage was void, the property to be divided as that of a partnership. Knoll v. Knoll, 176 Pac. 22 (Wash.). It is well settled that the vaUdity of a marriage contract depends upon the law of the place of celebration. Henderson v. Ressor, 265 Mo. 718, 178 S. W. 175; Dalrymple v. Dalrymple, 2 Hagg. Cons. 54. See i Nelson, Divorce AND Separation, § :i^. But although the contract by the lex loci contractus is
