RECENT CASES. 143 Constitutional Law — Interstate Commerce — Meat Inspection Law. — A Minnesota statute prohibits the sale of dressed meat within any municipal division of the State, unless the animal was inspected there within twenty-four hours before it was slaughtered. Held^ unconstitutional, as it, in effect, prohibits the importation of meats slaughtered in other States. This violates both the clause of the Constitution giving Congress the power to regulate commerce and the one declaring that the citizens of each State shall be entitled to all the privileges and immunities of citizens in the several States. State of Minn. v. Barber^ lo Sup. Ct. Rep. 862. Constitutional Law — Interstate Commerce — Original Packages. — An Iowa statute forbade the sale of intoxicating liquors within the State except in certain specified cases. Held^ unconstitutional, in so far as the statute prohibited the sale of liquors by a foreign non-resident importer in the packages in which they were brought from another State. Such a provision encroaches upon the power of Congress over interstate commerce, for this power does not stop at the boundary of the State, but can follow the article imported until it becomes mingled with the common mass of property within the State. This statute is more than a police regulation. The importation of liquors from one State into another admits of uniform treatment throughout the country. There- fore it is not a matter of a purely internal nature, and the silence of Congress upon the subject amounts to a declaration that such importation shall be free. Gray, Harlan, and Brewer, JJ., dissenting, Leisy v. Hardin^ 10 Sup. Ct. Rep. 681. See Lyngv. Michigan^ 10 Sup. Ct. Rep. 725, accord. Constitutional Law — Power of Congress over the Territories. — An act of Congress declared void the charter of the Church of Jesus Christ of Latter-Day Saints which had been granted by the Legislature of Utah. Held, that this was a valid exercise of the supreme legislative power which Congress pos- sesses over the Territories of the United States. Upon the dissolution of this religious corporation, its personal property became vested in the government of the United States, to be applied under the doctrine of cy pres to some kindred object. Fuller, C. J., and Field and Lamar, JJ., dissenting. Late Corpora- tion of the Church of fesus Christ of Latter-Day Saints v. United States^ 10 Sup. Ct. Rep. 792. Contracts — Fraud — Purchaser for Value. — An individual obtained, by bribing members of the city council, a contract to furnish the city with hydrants. His assignee in good faith and for value supplied the hydrants. Heldy that the city could not repudiate its agreement as against such innocent purchaser. Burlifigton Water Works Co. V. City of Burlington, 23 Pac. Rep. 1068 (Kan.). Contributory Negligence — Imputability of Parent's Negligence to Child. — The negligence of a parent cannot be imputed to a child, so as to bar an action by the latter for the wrongful act of another. Chicago City Ry. Co. v. Wilcox y 24 N. E. Rep. 419(111.). Illinois has generally been counted as following the so-called " New York rule" of Hartfieldv. Roper xy-^on the subject. See i Shearman & Redfield on Negligence, 4th ed., § 74, note 6. The court, in now adopting the •* Vermont rule," of non-imputa- bility {Robinson v. Cone, 22 Vt. 213), professes to correct those authors, and to dis- tinguish the cases cited by them as follows : *' In these cases the action was by an administrator for the benefit of the parents as next of kin. These cases are so clearly distinguishable from those in which the child himself sues, that they must have been cited by mistake." This same court, in Holton v. Daly, 106 111. 131, 1882, declared that this statutory action by the administrator for the benefit of the next of kin was simply a continuation of the right of action which would have accrued to the de- ceased himself had he survived the injury. To reconcile these decisions, and bring the cases attempted to be distinguished under the rule which forbids an action by the negligent parent for loss of service, it would seem that it ought to appear affirma- tively that in the cases in question the negligent parents were the only next of kin to be benefited by the action. So far from this being the case, in some of them the negligent parent was killed in the same accident as the child. Considering, how- ever, that in the large majority of cases the parents will reap the entire benefit, the distinction here laid down may not, as a piece of rusticum judicium, be so very objectionable. Equity Jurisdiction — Nuisance — Electric Railways. — In the present state of electrical science, a telephone company cannot enjoin the operation of an
