NOTES. 395 of his victim. If no title passes from the deceased to the murderer, his purchaser gets none, however innocent. But if the murderer gets a title, although as a constructive trustee, an innocent purchaser from him will acquire a title free from the trust. This distinction was in- volved in Shellenberger v. Ransom. A father murdered his daughter in order to inherit her property, and, four days later, sold the property to a third person. The court, reading into the statute of descent a disinheriting clause, as the majority of the court in Riggs v. Palmer had read into the Statute of Wills a revoca- tion clause, decided that the daughter's property did not descend to the father, because of his crime, and consequently declined to consider the question of the purchaser's good faith, although this should have been the cardinal point of the case. It is believed that the so-called fusion of law and equity is largely responsible for such decisions as those under discussion. The advantages of vesting a court with both legal and equitable powers are not to be denied. But when the doctrines of equity are no longer administered in a separate court, it is all the more important not to lose sight of the fundamental distinction between law and equity, — a distinction as eternal as the difference between rights in rem and rights in personam. We recommend to the attention of all our readers Professor Lang- dell's annual report as Dean of the Harvard Law School.^ It is now twenty years since the present system was introduced at the school by Professor Langdell, and the report presents a brief history of this period. We quote a few passages : — "In 1869-70 there were no examinations either for admission to the school or for a degree ; and those who received the degree of Bachelor of Laws at the close of that year were required to show only that they had paid the tuition fees for a year and a half. ... On the other Land, all those who received a degree at the close of the year 1889-90 had passed three successive annual examinations, each upon a full year's work, thus making three years' work in all. All of them had been in the school two full years, and all but four of them had been in the school three full years. Moreover, all of them who were not grad- uates of colleges had passed an examination for admission, either in Latin or French, and also in Blackstone's Commentaries. "In 1869-70 the teaching force of the school consisted of three professors. Now it consists of five full professors, one assistant pro- fessor, and three lecturers. . . . " In 1869-70 the amount of instruction given was ten hours per week (sufficient only for a single class). In 1889-90 the amount of instruction was thirty-five and one-half hours per week, and the amount now given is forty hours per week. "In 1869-70 the total number of students in the school was 156, of whom 99 were in the school only a part of the year. In 1889-90 the total number of the students in the school was 262, of whom all but 33 were in the school during the entire year. . . . "Prior to 1870-71 the student was expected to acquire his knowl- edge of law by studying certain prescribed text-books or treatises, and 1 Annual Reports of the President and Treasurer of Harvard College, 1889-90, Cambridge, Mass. Published by the University, 1891, pages 126-136.
