An annual firemen's relief fund is provided, to be paid out of money received from taxes on fire insurance companies doing business in the state, to be paid to persons injured while doing service as firemen, or if killed, to their widows and children, and if none, to their next of kin dependent on them for support.

It is required that every foundry in the state employing ten or more men shall provide suitable toilet rooms, heated and ventilated, for use of its employees. This act shows the increasing disposition of the state to look out for the welfare of the working classes, but it is difficult to see any reason why its provisions should be limited to foundries.

The State Board of Agriculture is authorized to appoint a state nursery inspector and to provide for the protection of nursery stock from injurious insects and diseases. This act was made necessary on account of the spread of the San Jose scale.

Changes are made in the laws relative to education which shows the growing disposition toward consolidation and centralization of the educational affairs of her school districts.

SOUTH CAROLINA.

South Carolina has shown her revived confidence in the federal government by so broadening her laws relating to eminent domain as to authorize the United States by proceeding in the state courts to acquire lands needed for the "public of the United States.

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An act was passed encouraging the establishment of libra ries in the public schools of the rural districts.

A Department of Agriculture, Commerce and Immigration is established, providing for the appointment and compensation of a commissioner.

Foreign corporations are given the right to locate and do business in the state in like manner and with like powers as corporations of a like kind and class created under her own laws, subject to certain terms and conditions not at all prohibitive or unduly onerous.

It is made a misdemeanor wilfully to withdraw or cause to be withdrawn and appropriated the electric current from the wires of any person or company producing or furnishing the same.

The jurisdiction of the state railroad commissioners is extended over all telephone lines, stations and exchanges and over all persons, firms and corporations owning or operating any telephone line, station or exchange for the transmission of intelligence for hire.

Railroad companies are practically exempted from the operation of the earlier statutes which made void mortgages of corporations not providing for all pre-existing bonds, debts and liabilities and limiting the liens of mortgages to twenty years unless some memorandum of payment or acknowledgment was recorded upon the face of the record of the mortgage.

An act establishes a state board of examiners for the regulation of the practice of medicine, and the false marking, branding, stamping or labeling of food products, whether mixed, manufactured or unmanufactured, is prohibited.

Another act provides against delays in the transportation of freight by railroads in the state and prescribes times respectively when shipments must be carried and delivered to points within certain distances from the point of shipment.

Constitutional amendments have been submitted: (1) providing for biennial sessions of the General Assembly; (2) permitting the General Assembly to enact local and special laws on the subject of laying out, opening, altering and working roads and highways, and as to the age at which citizens shall be subject to road or other public duty; (3) amending section 7 of her constitution relating to municipal bonded indebtedness.

VIRGINIA.

The legislation of Virginia during the year is of exceptional importance. It is found in the acts of the prolonged extra session, which extended through 1902-3-4 and also in the general session held this year. The general purpose of this legislation is to adapt the laws of the old commonwealth to her

new constitution, adopted in 1902. The laws of especial importance are those relating to the State Corporation Commission, a body consisting of three members and created by the constitution through appointment of the governor confirmed by the legislature. The procuring and amending of charters is largely under the jurisdiction of this commission. The provisions are very liberal toward the corporations and enable three or more persons to obtain a charter for any lawful business on almost any terms they desire by applying therefor and paying the charter tax, which is a graduated one. So far as private corporations are concerned, it is clearly the policy of the state, as disclosed in these laws, that they shall play an important part in business life. This commission is given extensive visitorial powers over corporations.

The act concerning public service corporations is of much more than ordinary interest. These corporations are defined as including transportation and transmission companies, turnpike and other internal improvement companies, and gas, pipe line, electric light, heat, power and water supply companies, and all persons, firms, partnerships, associations or corporations authorized to exercise the right of eminent domain, or to use or occupy any public highway, whether along, over or under the same, in a manner not permitted to the general public, but excluding all municipal corporations and public institutions owned or controlled by the state. These corporations are placed under the control and dominion of the state corporation commission. The commission is clothed with the powers of a railroad commission, and the regulation of rates. I should be tempted at this stage to review at some length the features relating to the regulation of transportation companies and their rates were it not for the exceptionally able article prepared by Mr. Braxton, of the Virginia Bar, and published in the July-August number, 1904, of the American Law Review. Suffice it to say that the commission is clothed with executive, legislative and judicial powers, and this seems to have been contemplated by the constitution, for in its

article relating to the division of the powers of government, legislative, executive and judicial departments are required to be kept separate and distinct, so that neither may exercise the powers properly belonging to either of the others, nor may any person exercise the powers of more than one of them at the same time, subject to the significant qualification "except as hereinafter provided," and then follows in another place a provision granting the legislative, executive and judicial powers to the state corporation commission, in the regulation of public service corporations. In the original constitution of Virginia drafted by Jefferson there was no such exception, his idea being to keep these departments separate and distinct at all times and places.

Careful provisions are made for an appeal to the Supreme Court of Appeals from all decisions of the state corporation commission of a judicial nature, and the remedies through the courts as against wrongful executive or legislative action are preserved.

By other acts, Virginia authorizes the recording of deeds on certificates of acknowledgment before a justice of the peace, a commissioner in chancery of a court of record or a notary "in the Philippine Islands, Porto Rico or any territory or dependency of the United States."

The failure of an attorney at law to pay over or deliver to the person entitled thereto, within a reasonable time after demand, any money, security or other property, which has come into his hands as such attorney, is made a sufficient ground for revocation or suspension of his license.

Attorneys are given a lien for their fees in all actions sounding in tort or for unliquidated damages on contract, and the act makes void against such lien, except as evidence of the defendant's liability on the cause of action, all settlements made between the parties where written notice of a claim to such lien has been given by the attorney.

The code is amended in relation to giving bribes to and their acceptance by public officers. The code provided for the

case of a bribe given "corruptly" or accepted "corruptly." The amendment omits the word "corruptly," and makes it an offense to leave the state for the purpose of giving or accepting any gift or gratuity to or by a public officer to influence his action and raises the punishment to confinement in the penitentiary instead of jail, as heretofore, and also forfeits the office in case of acceptance of the gift or gratuity.

Various changes are made in the law regulating the transportation of bodies of persons who died of contagious diseases. The changes are intended to protect the public against the spread of disease.

Debts due nurses and to sanitariums or hospitals in last illness, not exceeding fifty dollars, are preferred after funeral expenses.

An act permits children, where either parent was a slave, to inherit from the father, where the mother was recognized by the father as his wife and the child as his child.

To already existing cases of contempt of court for which summary punishment may be imposed by the court, there is added: "Obscene, contemptuous or insulting language addressed to a judge for or in respect of any act or proceeding had or to be had in such court, or like language used in his presence or intended for his hearing, for or in respect of such act or proceeding."

The time in which a decree for a divorce from bed and board may be changed to a divorce from the bond of matrimony, is reduced from five to three years after the first decree.

It is made a misdemeanor, punishable by fine and disbarment, for an attorney to print, publish, distribute or circulate any advertisement or printed matter offering to procure or aid in procuring any divorce, severance or annulment of any marriage or offering to engage or appear as attorney in any suit for alimony, divorce or dissolution of any marriage.

Another act provides for the taking of the deposition of the woman alleged to have been assaulted in a prosecution for rape in the presence of a judge, the commonwealth's attorney, the