40 HARVARD LAW REVIEW. ment, and was not excused because of the promise made to him to repair. Lewis v. N. Y. 6- N. E. R.R. Co., 26 N. E. Rep. 431 (Mass.). Agency — Revocation of Authority — Commission. — Where a real-estate agent is employed to find a purchaser, and there is no limit as to time, the principal may at any time revoke the authority. But if at the time of revocation the agent had a negotiation pending for the sale, which the principal afterwards consummates, the agent is entitled to his commission. Knox v. Parker, 25 Pac. Rep. 909 (Wash.). Bailment — Jus Tertii — Defence by Bailee. — Defendants held goods as warehousemen of plaintiffs, to whom they gave delivery-orders to plaintiffs or order. Plaintiffs sold the goods to a third party, and endorsed the delivery-orders to him, but up to the time of trial the orders had not been presented to defendants. Plaintiffs gave defendants notice that they cancelled the endorsement of the delivery-orders, and demanded the goods, which the defendants retained on the ground that plaintiffs had no title to the goods, refusing the demand/i?r their own account, and not on behalf of the true owner of the goods. Held, that a bailee of goods cannot avail himself of title of a third person to the goods as a defence to an action by the bailor, except by further showing that he is defending the action on behalf and by the authority of such person. Rogers, Sons 6° Co. v. Lambert 6° Co. [1891], 1 Q. B. 318, Ct. of App. (Eng.). Bills and Notes — Seal. — An instrument in the form of a negotiable promissory note, but with a scroll in which the word "seal " was written, after the signature of the maker, is a sealed instrument, and not a negotiable promissory note, though there is no reference to a seal in the body of the instrument. Osborne &° Co. v. Hubbard, 25 Pac. Rep. 1021 (Ore.). Conflict of Laws — Garnishment — Where the defendant is a resident of Illinois, and wages due him were earned there, the situs of the debt is Illinois; and though the plaintiff may have garnished the debtor while he was in Iowa, and the Iowa court thus have jurisdiction of the garnishment suit, yet by virtue of the princi- ples of comity the Iowa court will apply the Illinois exemption laws to such wages. Mason v. Beebee, 44 Fed. Rep. 556 (la.). Copyright — Dramatizing a Novel. — An action was brought by executors of A, to restrain the defendant from representing a certain drama in infringement of the plaintiff's stage copyright. A had first published a novel, and afterwards had published a dramatized version of his own novel. The defendant's drama was dramatized directly from the novel, after the publication of the dramatized version by A, but not with the help of his version. Held, that A having published the novel before the drama, any person had a right to dramatize the novel and represent the drama, and that therefore the action failed. Schlestnger v. Bedford, 68 L. T. N. S. 762 (Eng.). A like action was also brought in the following case : A had first published a drama, and afterwards a novel founded on it. The defendant's drama was drama- tized directly from the novel, and not with the help of A's drama. Held, that A having published the drama before the novel, no one had the right to infringe the stage copyright in the drama, even though the passages complained of were taken from the novel and not from the drama of the author. Schlesinger v. Turner, 63 L. T. N. s. 764 (Eng.). Corporations — Not Persons — Interpretation of Contract. — A lease of land, with an iron furnace and a mill, and certain water-rights for purpose of working the same, contained a covenant on the part of lessees not to assign or underlet with- out consent in writing of the lessors, " such consent not to be unreasonably refused, or refused to a person of responsibility and respectability." The lessees agreed with the corporation of a borough to assign to them, and the corporation agreed with the lessees not to use the water-rights for manufacturing iron or steel. The lessors re- fused to consent to the assignment, on the ground that the corporation could not use the premises for the purposes for which they were intended. Held, that the corpora- tion was not, under the terms of the lease, "a person of responsibility and respecta- bility," within the meaning of the covenant therein, and that the consent had not been unreasonably withheld. Harrison, Ainslie, &> Co. v. Corporation of Barrow-in- Furness, 39 W. R. 250 (Eng.). Damages — Punitive Damages not Allowed. — In Washington punitive dam- ages cannot be recovered for personal injuries, however occasioned. Spokane Truck <S^ Dray Co. v. Hoefer, 25 Pac. Rep. 1072 (Wash.).
