4io HAR VARD LA W RE VIE IV. tion so that it does not exempt it from the particular tax complained of, there is no impairment of the obligation of the contract between the State and the corporation by any subsequent law of the State, and the Supreme Court of the United States has no jurisdiction. St. Paul M. & M. Py. Co., v. Todd County Minn., t2 Sup. Ct. Rep. 281. Here the tax was assessed under the general taxing-laws in force at the time of granting the charter; there was, therefore, no subsequent law which could be said to impair its obligation. The assessment was a purely ministerial act, and not a law of the State, and so not within the constitutional prohibition. This differs in the above particular from ■ cases where a subsequent law enters into the case, and where it is settled that the United States Supreme Court has juris- diction to review the State court's construction of the contract. Constitutional Law — Interstate Commerce — Tax on Goods. — A statute requiring all merchants to pay a tax of " one-tenth of one per cent, on the total purchases in or out of the State " does not interfere with interstate commerce within the meaning of the Constitution. It is a tax on the goods, and not on the privilege of purchasing them. Ex parte Brown, 48 Fed. Rep. 435- Constitutional Law — Protection of Witnesses — Self-criminating Testimony. — Revised Statute, i860, provides that no "evidence obtained from any party or witness by means of a judicial proceeding . . . shall be given in evidence, or in any manner used against him, or his property or estate, in any court of the United States, ... in any criminal proceeding, or for the en- forcement of any penalty or forfeiture." I/eld, that, as this provision would not prevent the use of testimony so obtained to search out other testimony to be used against the witness, the protection afforded is not coextensive with that of the fifth amendment, which declares that no person " shall be compelled in any criminal case to b6 a witness against himself;" and hence a witness in any criminal investigation in the federal courts may still refuse to answer, on the ground that this testimony will tend to criminate himself. 44 Fed. Rep. 268 reversed. Counselman v. Hitchcock, 12 Sup. Ct. Rep. 195. See articles on this case in 5 Harv. Law Rev. 24. Contracts — Illegality — Interstate Commerce Rates. — The inter- state commerce law makes it penal for a carrier to issue bills of lading at rates different from those filed with the commission, or to demand or receive freight charges variant from such established rates. The act makes it penal for any person to knowingly obtain transportation at less than the established rates. Defendant agreed to carry goods from Illinois to Alabama over its own and a connecting line. The bill of lading called for $5 freight charges, but the con- necting line refused to deliver up the goods to the plaintiff, the consignee, ex- cept on payment of $29, the schedule rate. Neither plaintiff nor consignor knew the schedule rate. Held, the plaintiff may recover the value of the goods. He was not bound to know the published schedule of rates. Mobile i£ O. P. v. Dismukes, 10 So. Rep. 289 (Ala.). Corporations — Exemption from Taxation — Liability to Municipal As- sessments. — A charitable corporation exempt by law from all taxation is liable under a municipal assessment for repairing the street in front of its property as such obligation is not imposed under the taxing power, but is in the nature of a police regulation. City of Philadelphia v. Contributors to the Pennsylvania Hos- pital, 22 Atl. Rep. 744 (Pa.). Corporations — Limitation of Indebtedness. — Constitution of Iowa pro- vides that municipal corporations shall not incur indebtedness beyond a limited amount. Statute provides that they may issue new bonds in exchange for old bonds, or sell them and apply the proceeds to paying off the old ones. A cer- tain township, whose indebtedness already exceeded the constitutional limit, issued bonds under said statute. Held, that the bonds are unenforceable, as is- sued in excess of the amount allowed by the constitution. Brown, Harlan, and Brewer, JJ., dissenting. Dist. Township of Doon, I ynn Co., la., v. Cummins, 12 Sup. Ct. Rep. 220. The point of difference between the majority and the minority was this: These new bonds, being only in exchange for the old bonds, in no way increased the town's indebtedness, and so, the minority said, did not violate the constitution; while the majority construed the constitution more strictly, and pointed out that
