338 HARVARD LAW REVIEW. whatever be the nature of the trade. It is not that an alien has an inher- ent right to sell liquor, but that he has a right not to be debarred merely because he is an alien. Would the Maryland Court of Appeals, in view of the history of the Fourteenth Amendment, support a statute forbidding any negro to sell liquor? In Trageser v. Gray the provision in question was only one clause of a statute raising the license fee and imposing on the liquor trade other restrictions not unlike those in Crowley v. Christensen, ii Sup. Ct. Rep. 13,^ and plainly constitutional. As the plaintiff undertook to treat the whole statute as invalid, and demanded a license under the provisions of the statute previously in force, the decision of the case may be supported consistently with the views here suggested; and it is noticeable that two members of the court, including the Chief Justice, while concurring in the judgment, state that their reasons are not those of the majority. If the Supreme Court of the United States has occasion to pass upon the consti- tutionality of the alien clause, it may be seriously doubted whether the decision of the Maryland court will be sustained. The Incorporated Council of Law Reporting for England and Wales has decided to begin a new series of reports. The change is entirely unnecessary and has caused a good deal of grumbling in England, as the advantages of it are not very apparent and it necessitates a new method of citation. It was hard enough before to avoid confusing i Q. B., L. R. i Q. B., and i Q. B. D., but we must now add [1891] i Q. B. The cita- tions for the new series will be as follows: Chancery Division [1891] i Ch. [1891] 2 Ch. [1891] 3 Ch. Queen's Bench Division [1891] i Q. B. [1891] 2 Q. B. Probate Division [1891] P. Appeal Cases [1891] A. C. In 1892 they will be [1892] i Ch., etc. RECENT CASES. [These cases are selected from the current English and American decisions not yet regularly reported, for the purpose of giving the latest and most progressive work of the courts. No pains are spared in selecting ail the cases, comparatively few in number, which disclose the general prog- ress and tendencies of the law. When such cases are particularly suggestive, comments and refer- ences are added, if practicable.] Admiralty — Joint Tort-Feasors. — Where vessel A. has been injured by the negligent management of vessels B. and C, the admiralty rule as to damages is the same as the common-law rule; the entire damage may be recovered from either one, if the plaintiff chooses. The American rule, that in the first instance only half can be recovered from either one, and, in addition, the balance only, which the plain- tiff cannot enforce against either, being recoverable from the other, does not hold in England. The Avon [1891], P. 7 (Eng.). Admiralty — Maritime Lien. — The plaintiff agreed to remain on board ship while it was at the dock. Held, he had a maritime lien for wages so earned. Reg. V, Judge of City of London Court, 63 L. T. Rep. n. s. 492 (Eng.).
- See 4 Harv. L. Rev. 236.
