on Columbus," regarded as an invaluable work. He was also author of the article on "Whist" in Appleton's Encyclopædia.
Ex-Congressman Edmund Rice died at White Bear, Minn., July 11, at the age of seventy. He was a native of Waitsfield, Vt., and removed to Kalamazoo, Mich., read law, became register and master in chancery, and finally clerk of the Supreme Court of the third circuit. After the Mexican war, in which he served as a common soldier and in the commissary department, he practised law at St. Paul, Minn. Mr. Rice served in the Territorial Legislature, and in both branches of the State Legislature of Minnesota, and was twice Mayor of St. Paul. He was elected a representative to the Fiftieth Congress.
Hon. A. G. Lebroke, of Foxcroft, Me., for many years prominent as a lawyer, died July 19. Mr. Lebroke had always taken a deep interest in all public affairs, and served his State and district in the Maine Senate for two terms. He was considered one of the ablest lawyers in Eastern Maine.
John C. Elmendorf, of New Brunswick, N. J, whose death occurred on July 19, was a brother-in-law of Frederick T. Frelinghuysen, Secretary of State under President Arthur, and was for years one of the leading lawyers of the New Jersey Bar. He was born near Somerville, N. J., in 1814. For fifteen years he was prosecutor of the Pleas of Middlesex County, trying many important cases. He was for years treasurer of Rutgers College, occupying that position at his death.
Charles A. Heath, a prominent lawyer of Vermont, died in Barre on July 22. He was an ex-President of the Vermont Bar Association, ex-Senator for Washington County, and an influential citizen of Montpelier.
REVIEWS.
The Law Quarterly Review for July is filled with interesting matter. The leading article is a paper on "Specific Performance and Laesio Fidei," by Lord Justice Fry, in which the author traces the history of his subject from the days of Saint Paul, and attributes its origin to the Courts Christian. The other contents are articles on "Une École des Sciences Politiques," by Max Leclerc; "Possession for Year and Day," by F. W. Maitland; "On the Rejection of Hearsay," by Lewis Edmunds; "The Land Transfer Bill," by Hugh M. Humphry; "The New Italian Criminal Code," by T. Boston Bruce; and "A Reply on the Factor's Acts," by John R. Adams.
The Journal of Jurisprudence (Edinburgh) for July, commenting on the action of the Supreme Court of the United States in the "Oregonian Case," says: "The whole story suggests a reflection which must often be present to the minds of those on this side of the Atlantic who have business relations with America. Why is it that such a sense of insecurity prevails in regard to all American investments? Why is it, for example, that it is easier to get 6 per cent over real property in America, than 4 per cent in this country? It is not that America is distant, for the electric wires and the ocean racers have brought America very near to our doors. It is not that America is a back-going country, for her expansiveness is tenfold greater than our own. It is not that the American Government is unstable, for her constitution has stood the test of a century. But it is because of the insurmountable dread that the negotiations will be vitiated by a swindle, and that the swindle will be one for which the law will give no remedy. This dread is born of experience. The history of British investments in America is strewn with memories of swindles for which the American courts have been powerless to find redress."
There is more truth than poetry in the foregoing remarks, to our shame be it said. But unfortunately, our British brethren have not been the only victims of wily schemers. The hard-earned savings of many an industrious American laboring man have been swallowed up by the same law-evading swindlers.
"The Jurisdictions and Duality of Sheriffs" and "The Stamping Regulations " are the leading articles of the July number of the Scottish Law Review. In the "Notes from London" the writer, commenting upon judges seizing every oppor-
