222 HARVARD LAW REVIEW. (entitled " Hints to Young Lawyers,") there is one passage which will be especially interesting to those who have studied in the Harvard Law School within the last twenty-five years. Mr. Carter says : ' ' The im- portance to the lawyer, and especially to the young lawyer, of making each task he may be called upon to perform the special means of enlarging and disciphning his own powers will be better understood if we consider the different degrees of ease with which the same knowledge may be acquired under different conditions of the mind. When the student, under the influence of no other motive than the feeling that it is neces- sary for his general purposes, applies himself to the study of some special subject, he is obliged to compel the attention by a conscious exertion of his will, — always a painful labor; the work soon becomes irksome, the attention is constantly diverted, the impression on the mind is slight and evanescent, and the task is apt to be thrown aside in disgust. Far other- wise, however, when the lawyer is employed upon some concrete question arising in the actual affairs of men, when there is an immediate object in view ; . . . the whole mind is wakened into activity, and experiences the highest of intellectual pleasures, that of overcoming difficulties ; it is not satisfied with one acquisition, but demands more ; what would otherwise be work becomes play." And, Mr. Carter goes on, "You will begin to see that the law consists of a few general principles, and that its vari- ety and difference proceed only from the infinite variety of the facts with which it deals." He is speaking, as his context shows, of the actual working up of a case in practice. Nevertheless, the case system of instruction, to its credit be it said, is fairly described by his words. No one can study law with the actual cases before him without seeing the dramatic force of the situations which they present, or without experien- cing " the highest of all intellectual pleasures " in mastering for himself the difficulties which have been struggled with by past and present gen- erations of judges in their attempts to apply "a few general principles of justice " fo the infinite diversity of the facts which have been brought before them by Angus and Dalton^ Perrin and Blake^ Patch and White, JDred Scot and Sandford^ and the millions of less known litigants, whose troubles have been none the less real, though they serve now only to add bulk to the digests. There are, and will be, men who study law only because they see in it a necessary means to a living, as they would work a treadmill in the poorhouse ; but to those who will care for their pro- fession, and love it as it deserves to be loved by its every member, a distinguishing merit of the case system of study is to be found in that close friendship with the courts in their actual work of doing justice which Mr. Carter urges, and which his forcible oratory should inspire. In another respect also Mr. Carter's address is valuable ; for when a man of his standing in the profession speaks out to his juniors from his own experience they cannot fail to get some insight into the causes of success ; and a man of his standing rarely speaks out so freely. Can One cheated into pleading Guilty maintain an Action for iT?-;-In yohnson v. Girdwood, 28 N. Y. Suppl. 151 (N. Y. City Common Pleas), it appeared, upon demurrer to the complaint, that the plaintiff was arrested and prosecuted on the false and mahcious complaint of the de- fendant, and that on the representation of the defendant that a plea of guilty " would benefit the plaintiff, and would terminate the proceedings
