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money. The vendees reserved the right to sell any of this furniture for the purpose of purchasing other and better furniture to put in the hotel. Held, that the mortgage was void ab initio as to creditors and incumbrancers. Brasher v. Christophe, 15 Pac. Rep. 403 (Col.).

Mortgage, ChattelTitle to Increase.—Under the Maryland Code a chattel mortgage is good without possession if it is recorded. Such a mortgage was given on “fifteen shoats.” Nearly ten years later remote descendants of these shoats were sold under an execution against the mortgagor, who had never given up possession. The mortgagee claimed them against the vendee and succeeded. Cahoon v. Miers, 11 Atl. Rep. 278 (Md.).

This seems to be logical enough, but it suggests very pointedly the propriety of further legislation if a mortgage of chattels is in any case to be held good against third persons without a change of possession.

PatentDriven Wells.—Section 7 of the Act of March 3, 1839 (5 Stat. 354), has been interpreted as rendering uupatentable any invention publicly used more than two years before a patent is applied for, even though such use be without the knowledge or consent of the inventor. And on this ground the “Driven Well” patent has been overthrown, after withstanding for twenty years persistent attacks in the Circuit and Supreme Courts. See Eames v. Andrews, 122 U.S. 40; Andrews v. Hovey, 8 Sup. Court Rep. 101.

Promissory NotesBankruptcy of Maker and Indorser.—The holder of a note received a dividend from the indorser’s assignees in bankruptcy, and was then allowed to prove for the whole amount of the note against the bankrupt estate of the maker. He could recover only the balance due. Southern Michigan Nat. Bank v. Byles, 34 N. W. Rep. 702 (Mich.).

Quasi-ContractStatute of Frauds.—The plaintiff contracted orally with the defendant that the latter should instruct his son in dentistry for two years for a certain consideration. After a few months the boy left defendant, and the plaintiff sues on quantum meruit, for his services. Held, the contract not complying with the statute of frauds cannot be set up by the defendant as a defence. Freeman v. Foss, 14 N.E. Rep. 141 (Mass.).

Saloon-Keeper.—Plaintiff and one F became intoxicated on liquor furnished them by the defendant in his saloon. F pinned a piece of paper on plaintiff’s back and set fire to it, and serious injuries resulted. The defendant was held liable. “When one enters a saloon or tavern, opened for the entertainment of the public, the proprietor is bound to see that he is properly protected from the assaults or insults, as well of those who are in his employ as of the drunken and vicious men whom he may choose to harbor.” Rommel v. Schambacher, 5 Lancaster Law Review, 8 (Com. Pleas, Philadelphia Co., Pa.).

Trusts, ConstructiveConfidential Relation.—Plaintiff purchased land of a corporation. The latter was indebted for a part of the purchase-money, and an action was brought to compel payment or a sale of the land. An officer of the corporation assured the plaintiff that his title would be made good. A sale was ordered; this officer became the purchaser, and then refused to confirm the plaintiff’s title. Held, that as between the parties the title to the property would be treated as in precisely the same situation that it was in when the plaintiff was assured that his rights would be protected. Allen v. Jackson, 13 N.E. Rep. 840 (Ill.).

Compare Appeal of McCall, 11 Atl. Rep. 206 (Pa.); Jenninas v. Langdon, 11 Atl. Rep. 212 (Pa.), and cases collected in Ames’ Cases on Tmsts, 291, n.

WillEffect of Codicil.—Chas. O’Conor put a clause in his will releasing all demands against the persons named “in this will.” Later he executed a codicil republishing the will with a bequest to the defendant. Nothing was said about releasing any demands against him. The executor now sues for a $50,000 fee of his testator for services in the Tennessee bondholder’s case. Held, the word “will” did not include the codicil. Sloane v. Stevens, 25 Cent. L.J. 540 (N.Y.); 13 N.E. Rep. 618, s.c.