282 HARVARD LAW REVIEW. One may fairly argue that the inducement held out might very well have led the woman to lie, in order to obtain the charm or talisman. She might think it of great value to her, even though she was innocent. But granting the court's position, that the favor promised was one that would induce none but a guilty person to confess, have we here the true test of admissibihty ? Are confessions obtained by promises of favor to be excluded for the sole reason that they lack credibility? There are numerous dicta to that effect. So Keating, J., in Reg. v. Reason, 12 Cox, 228; Littledale, J., in Rex v. Court, 7 C & P. 486; and Coleridge J., in Rex V. Thomas, 7 C. & P. 345. But in none of these cases, or others hitherto decided, has it been necessary to go so far as to hold that the sole ground of exclusion. May it not be that the true ground is an aversion on the part of English-speaking peoples to the use in criminal cases of evidence obtained by such questionable means? May it not be from a spirit of fair play to the defendant? That would seem to be the reason why confessions obtained by threats are excluded. At all events, such a feeling has always had great influence on the minds of English and Ameri- can judges. Whether it is wise to be so careful of the prisoner is another and larger question. Protests against such an excessive solicitude are not wanting to-day, and among them one may, perhaps, count this North Carolina case. Admission to the New York Bar. — In the latest rules of the New York Court of Appeals in relation to the admission of attorneys and counsellors-at-law, an important relaxation is noticeable in the rather draconic severity on this subject that has characterized that State. In the past, one year's study in a local office has been an indispensable and rather appalling requisite ; but, according to the rules promulgated on October 22, that is now done away with, and different qualifications substituted in its stead. To entitle an apphcant to an examination, he must now have studied law for three years, "except that if the applicant is a graduate of any college or university, his period of study may be two years instead of three." This requirement may be fulfilled "by serving a regular clerkship in the office of a practising attorney of the Supreme Court in this State after the age of eighteen years ; or after such age, by attending an incorporated law school, etc., etc. ; or by pursuing such course of study, in part by attendance at such law school, and in part by serving such clerkship." If the applicant be a graduate of a college or university, he must, however, have pursued the prescribed course of study after his graduation. The effect of this change on our Law School will, undoubtedly, be a beneficial one. Men who have not been graduated from college can now prepare for New York Bar examinations, as quickly here as any- where, while, since the two years' study required from college graduates must be after graduation, Harvard seniors will find a leave of absence from the college and three years' study here, their very best method of preparation. To all college graduates, also, now that the shadow of the local office rule has been removed, the Harvard Law School can offer as great facilities for expeditious preparation as any law school in the land. Chandelor v. Lopus. The case of Chandelor v. Lopus, a famous land- mark of the law of deceit and implied warranty, is reported as of Trinity
