520 HARVARD LAW REVIEW, the cases for which the learned writer failed to find an intelligible theory. Judge Holmes seems to have been also confused by cases of adjudicated liability not properly falling within the categories either of commanded acts or of acts represented to be commanded. These cases, however, are justifiable on no theory at all. They rest, not upon fiction, but upon injustice and departure from the real relations, and no explanation of them is required, or even possible. I hold the fact to be that whenever a man conceives a purpose and procures its accompHshment ostensibly as his act, whether by machine or by another individuality, the act so done is his act in every legitimate and truthful sense, and that a resort to a fiction to sustain a legal responsibility for it is quite unnecessary. In conclusion, it is to be added that one great object of this arti- cle will be effected, if I have made clear, in addition to some diffi- culties of my strict subject matter, the fact that legal relations may be extremely complicated, that they cannot be successfully handled without taking into view all the persons between whom the relations subsist and all the relations subsisting between those persons, and that just as there are bilateral relations, so there may be trilateral, quadrilateral, or even multilateral, relations. As the restrictions of ancient procedure are swept away, we should find less difficulty in dealing with these complications, and a more systematic under- standing of them than has ever existed in the past should be the portion of the future. Everett V. Abbot. New York, February 4, 1896.
