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Harvard Law Review. Published monthly, during the Academic Year, by Harvard Law Students. SUBSCRIPTION PRICE, $2.50 PER ANNUM 35 CENTS PER NUMBER. Editorial Board. Hugh W. Ogden, Editor-in-Chief. Justin D. Bowersock, Treasurer. Edward R. Coffin, Logan Hay, Robert Cushman, Wiilliam H. S. Kollmyer, Robert G. Dodge, Herbert C. Lakin, Louis A. Frothingham, Arthur M. Marsh, Edward K. Hall, Archibald C. Maiteson, James P. Hall, Edward Sandford, Livingston Ham, Henry Ware. Hon. Charles Doe, Chief Justice of the Supreme Court of New Hampshire, who died suddenly on March 9, 1896, was a valued contribu- tor to this Review, being the author of " A New View of the Dartmouth College Case," 6 Harvard Law Review, 161-181 and 213-222; and " Lease of Railroad by Majority of Stockholders with Assent of Legis- lature," 8 Harvard Law Review, 295-316 and 396-414. His official tenure was almost unique. Appointed to the Supreme Bench in 1859 ^^ ^^^^ ^^^V ^S^ ^^ twenty-nine, he continued there, with the exception of two years (1874-1876), until his death at the age of sixty-five ; thus passing more than half his life in the discharge of judical duties. Judge Doe's reported decisions have given him a deservedly high reputation outside the limits of New Hairpshire, and some of them have seldom been surpassed. But his extraordinary ability was fully known only to those who came in personal contact with him as practitioners or associates. The rapidity with which his mind worked was simply mar- vellous, vividly recalling the discriptions given of the late Master of the Rolls, Sir George Jessel. The moment a case was stated, he could generally discern at once the vital issue ; and was usually able, as soon as the case was submitted, immediately to express an opinion in short, crisp sentences, which not only completely disposed of the matter in hand, but caused everybody to wonder how there could ever have been any doubt about the result. In keenness of analysis and in the faculty of terse and vigorous expression he combined qualities of the highest order, which are not often found united in one person. A few of his written opinions may be open to the objection of over-elaboration. But there was never any obscurity or prolixity in his oral utterances, and a large proportion of his reported decisions are models of con- densation and clearness. In a humorous sketch read by a bright young lawyer before a Bar Association, Doe, C. J., is represented as rendering a certain decision and giving as the sole reason "that the law has hitherto always been under-