REVIEWS. 97 of his death ; but the provisions of this item shall vest in the said son only a life estate in said lands, and nothing more." Held, that the words describing those entitled after the son's death are words of purchase, and not of inheritance, and the rule in Shelley's Case does not apply, and the son took only a life estate. Earnhart v. Earnhart, 26 N. E. Rep. 895 (Ind.). Real Property — Statute of Limitations — Independent Adverse Hold- ings. — In Alabama independent adverse holdings of land cannot be added to make up the statutory period and bar a recovery; but some privity must be shown between the adverse holders. Lucy v. Tennessee &• C. R. Co., 8 So. Rep. 806 (Ala.). Statute of Limitation — Conversion — Demand and Refusal. — A lease belonging to the plaintiff was fraudulently taken from him by his son and deposited without his knowledge with B in 1881, as security for the repayment of money lent by B, who held the lease without knowledge of the fraud. B having become bankrupt, his trustee in 1889 assigned the debt to the defendant and handed the lease over to him. Subsequently the plaintiff demanded the lease of the defendant, and on his refusal to return it sued for detinue and conversion, to which the defendant pleaded the Statute of Limitations. Held, that the statute began to run from the time when the plaintiff first had a complete cause of action against the defendant, irrespective of the question whether he had a previous cause of action against B ; that the statute, therefore, only began to run from the date of the demand and refusal, and was no answer to the action (following Spackman v. Foster, L. R. 11 Q. B. D. 99). The deci- sion contained a dictum by Lord Esher that if one man is guilty of a wrongful conver- sion, and afterwards a second man converts the same thing, the cause of action against the second man is not barred by the statute, though the cause of action against the first man accrued more than six years before the second conversion ; that the property in chattels is not changed by the Statute of Limitations, though more than six years has ?, elapsed. Miller v. Dell [1891], 1 Q. B. 468 (Ct. of App.) (Eng.) Wills — Right of Judgment-Creditor of the Heir to contest the Will OF Testator. — Testator, by his will, devised all his real estate to others fhan his only son and heir-at-law. Previous to testator's death one of the creditors of the son secured judgments against the son which became liens on all the real estate which the son had or might hereafter have. Held, that such judgment-creditor had a suffi- cient interest to entitle him to contest the validity of the will. In re Langevirts Will, 47 N. W. Rep. 1 133 (Wis.). Will — Ademption — Presumption against Double Portions. — Testator by his will bequeathed twenty-one twenty-fourth shares in a brewery business to his three sons as tenants in common. The eldest son, being employed as a manager in the business, pressed his father for an increase of salary. The father transferred to the eldest son two of the twenty-fourth shares in lieu of salary. Held, that in this case the presumption against double portions arose, and as that presumption had not been rebutted, the gift of the two shares must be treated as an ademption of the eldest son's one-third part, and he could therefore take only five of the remaining nineteen shares. Re Lacon, 64 L. T. Rep. N. s. 22 (Eng.). REVIEWS. A Treatise on the Law of Sales of Personal Property, including the Law of Chattel Mortgages. By Christopher G. Tiedeman, author of " Real Property,' 1 " Commercial Paper," etc. The F. H. Thomas Law Book Co. St. Louis, 189 1. 8vo. Pages 769. The author's purpose in publishing this new work on sales is, as he says in his preface, to supply a " comprehensive treatise of a distinctively American type." But in fact it is so comprehensive that it is more a digest than a treatise. Little space is given as a whole to the discus-
