39^ HARVARD LAW REVIEW, the instruction given consisted of lectures upon these same text-books, — a mode of study and instruction which has become in this school a forgotten piece of antiquity. Now the student makes his own text- book, and the subjects as well of study as of instruction are those original materials of the law which constitute the stock-in-trade alike of the judge, the practising lawyer, and the teacher. " In 1869-70 the library was so nearly a wreck that it required to be reconstructed almost from its foundations. Now it is believed to be larger (referring only to law-books proper, and excluding statutes), more complete, and in a better condition than any other law library in the United States, with the possible exception of the national library at Washington." There are also given many more details and tables of statistics, but these extracts are sufficient to show the marvellous progress which the school has made under the guidance of the present Dean and the unqualified success of the system which he originated. 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 all 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 addedj if practicable.] Admiralty — Warrant of Arrest — Issuance on Sunday. — Where a seaman learned that a vessel was about to proceed to sea, having unexpectedly changed her day for sailing, and that in consequence his wages would not be paid, it was held that a court of admiralty would allow a warrant of arrest to issue on Sunday, though the State law forbade the service of civil process on Sunday, and though, under section 914, Rev. St., such State regulation might apply to the law side of the courts of the United States. Pearson v. The Alsalfa, 44 Fed. Rep. 358. Bills and Notes — Collateral Security. — Plaintiff was the holder of an interest-bearing note, secured by a mortgage on land, which she had bought from the defendant investment company. The note bore interest-coupons which were payable at the business office of the defendant, and it was the defendant's custom to pay the coupons when due, whether or not the maker had already paid the interest. Held, that the receipt and payment of the coupons by the defendant was a purchase by it of the coupons, and not an extinguishment; and that in the event of a coupon not being paid iDy the maker of the note, the defendant, as holder of the coupon, was entitled to share pro rata in the security of the mortgage. Champion v. Hartford Investment Co., 25 Pac. Rep. 590 (Kan.). Common Carriers — Delay — Violence of Strikers. — A common carrier is not liable for dielay in the shipment of goods caused solely by strikers, who, by the use of lawless and irresistible violence, prevent his men from working. Missouri Pac. Ry. Co. v. Levi^ 14 S. W. Rep. 1062 (Tex.). Constitutional Law — Elections — Cumulative Voting. — Const. Mich., which provides for a representative form of government, and gives to every qualified male citizen the right to vote at all elections, impliedly prohibits any elector from casting more than one vote for any candidate for office. Hence, Acts Mich., 1889, No. 254, which provides that each elector may mass his votes upon one candidate for the office of State representative by casting as many votes for such person as there are representatives to be elected in the elector's district, is unconstitutional. Such act is unconstitutional for the further reason that voters in districts where only one representative is to be elected are placed at a disadvantage. Maynard v. Board Dist. Canvassers, 47 N. W. Rep. 756 (Mich.).
