152 HARVARD LAW REVIEW. are in fact navigable by the public in the conduct of useful commerce thereon, whether the waters of such stream be salt or fresh, or whether the tides of the sea ebb and flow therein or not." State v. Black River Phosphate Co., 9 So. Rep. 205 (Fla.). This is a distinct departure from the English rule. It is, however, sustained by the weight of American authority. Real Property — Escrow — Happening of Condition. — A deed in escrow becomes the deed of the grantee on the happening of the condition on which manual delivery should be made, and thereafter the depository is the mere agent or trustee of the grantee. White Star Line Steam-Boat Co. v. Morange, 8 So. Rep. 867 (Ala.). Real Property — Boundaries — Lakes. — Where land is conveyed bounded by a lake or stream, the grantee takes to the centre. Hardin v. "Jordan, 11 Sup. Ct. Rep. 808. For the dissenting opinion of Gray, Brewer, and Brown, JJ., that where bounded by a lake he takes only to the water's edge, see 1 1 Sup. Ct. Rep. 838. Real Property — Covenants in Deeds — Restrictions in Building. — Where the grantees, in deeds prohibiting the erection of a building, or projections therefrom, within a certain distance of a street, deliberately erect such projections, with full knowledge of the prohibition, and of the opposition of the grantor, the Commonwealth, the attorney-general cannot be held guilty of laches in waiting until the erection is completed before taking steps for its removal. Nor can the grantees, after persisting in the erection, contend that the projections are not of sufficient importance to warrant a mandatory injunction or order for their removal. Attorney-General v. Algonquin Club, 27 N. E. Rep. 2 (Mass.). Real Property — Telegraph Lines — Compensation to Abutting Own- ers. — A city cannot grant to a telegraph company the right to erect its line along a public street without first making compensation to the abutting property owners, since the line is an additional burden. Stowers v. Postal Telegraph Cable Co., 9 So. Rep. 356 (Miss.). There is considerable conflict of authority upon this point. See West. Union Tel. Co. v. Williams, n So. Rep. 106 (Va.), in accord with the principal case. For decisions the other way, see Pierce v. Drew, 136 Mass. 75, and Julia Bldg. Ass. v. Bell Tel. Co., 88 Mo. 258. In most jurisdictions the point has not been passed upon by the courts. Statutes — Intoxicating Liquors — Minors. — A minor whose civil dis- abilities as such have been removed by a decree in chancery is still a minor within the meaning of statutes prohibiting sales of intoxicating liquor. Coker v. State, 8 So. Rep. 874 (Ala.). Statutes — Territorial Courts. — Territorial courts, including the district court created for the district of Alaska, are not " courts of the United States," within the meaning of Rev. St. U. S. § 1768, which excepts judges of the courts of the United States from the authority therein given the President to suspend any civil officer appointed by and with the advice and consent of the Senate. McAllister v. United States, 11 Sup. Ct. Rep. 948. Wills — Acceleration of Legacies. — A testator bequeathed his personal estate to his wife for life, and provided that at her death certain specific legacies should be paid, and the residue should go to certain relatives. The wife, having renounced the will, took one-half the personal property absolutely. Held, that the specific legacies were thereupon payable in full at once, the wife's renunciation being equivalent to her death. In re Vance's Estate, 21 Atl. Rep. 643 (Pa.). Wills — Signature must be Subscribed — French Law. — An olographic testamentary writing containing the caption, " Testament d'Aglae Armant," but without signature at the end or following the testamentary dispositions, does not import such a signature as is required under the historical and rational interpretation of article 1588 of the Civil Code. The court said: "It is true that, in interpreting a like provision of the first English Statute of Frauds, an English court held that writing the name at the beginning of the testament supplied the absence of signature at the end; and some other courts, with that subjection to precedent which characterizes that system, followed the decision. But, though following it, some of the judges intimated that, if it were res nova, they would decide differently, and the doctrine was condemned by sound legists. And such was the prevalent dissatisfaction that an act of Parliament was passed
