A Fijian Court Day. of his professional career. In his opinion in the Slaughterhouse Cases Justice Miller said, "The eminent and learned counsel who has twice argued the negative of this ques tion has displayed a research into the history of monopolies in England and on the conti nent of Europe only equalled by the elo quence with which they were denounced." Although Justice Clifford's long service (1858-81) extended far into the next period of the court's history, his strong political convictions belonged to the past. He was a typical specimen of the old school Demo crat, tenacious of his opinions, and unyield ing to the changes of public sentiment. He steadily opposed the Federal tendencies re sulting from the successful suppression of the Rebellion. "Money is undoubtedly the sinews of war," he said in his dissenting opinion in Knox v. Lee; "but the power to raise money to carry on war, under the Con stitution, is not an implied power, and who ever adopts that theory commits a great constitutional error.1' Conservative to a fault, of somewhat aggressive judicial dig nity, and without any brilliant qualities of mind, he was, nevertheless, a very able and efficient judge. He had good sense, clear judgment and a boundless capacity for work. It is questionable whether any other member of the court ever bore a larger share of the varied labors of the court than this con scientious and hard-working judge. All the
special subjects of the court's jurisdiction— admiralty, revenue law, patents, trade marks, copyright—bear the impress of his indefatigable industry. In the consideration of these subjects he overcome to a large ex tent the very conservative tendency of his mind, and successfully applied recognized principles of law to new conditions. The cases in the note below will give a fair idea of his work. 1 1 United States v. Cruikshank, 92 U. S. 542; Tennes see i: Davis, 100 it. 257; Buffington r. Day, 11 Wallace 113; Knox f. Lee, 12 it. 457; United States v. Reese, 92 U. S. 214; Hobson v. Lord, 92 it. 397; Pollard i>. Lyon, i 0110225; The Lottowanna, 21 Wallace 558; Waring v. Mayor, 8 Wallace no; State Tonnage Tax Case, 12 it. 204; Hall r. De Cuir, 5 Otto 485; Ward -•. Maryland, 12 Wallace 418; United States r. Hall, 8 Otto 343; Holyoke Company r. Lyon, 15 Wallace 500; The Bel fast, 7 it. 624; Insurance Company r. dossier, 6 Otto 645; McAndrews v. Thatcher, 3 Wallace 347: The Lot towanna, 21 it. 558; The Comanche, 8 it. 448; Hobson ?•. Lord, 2 Otto 397; The Sunnyside, I it. 208; The Atlas, 3 i/i. 302; Dow r. Johnson, 10 it. 158; Powhatten r. Steamship Company, 24 Howard 247; Coleman r. Tennessee, 97 U. S. 509; Ford r. Surget, it. 594; Dela ware Mutual Insurance Company v. Gossler, 96 it. 645; McLean - •. Fleming, it. 245; Conrad r. Waples, it. 279; l'hu.-nix Insurance Company;'. The Atlas, 93 /A 302; Kiggs r. Johnson County, 6 Wallace 166; Miner r. The Sunnyside, 9 U. S. 208; Hatch r. Oil Company, 100 it. 124; The Star of Hope, 9 Wallace 103; The Kalorama, 100 it. 124; The Lulu, it. 192; The Maggie Hammond, 9 it. 435; Laramie Company v. Albany Company, 92 U. S. 307; Goodman r. Simonds, 20 Howard 343. And the following decisions on circuit: United States r. Holmes, i Clifford 98; ],awrence r. Dana, 4 Clifford 7; United States r1. Hartwell, 3 it. 221; Green r. Collins, 3 /A 494; James -•. Lycoming Insurance Company, /A 272; Hearn r. New Kngland Mutual Marine Insurance Company, 3 it. 318; Pendleton r. Kinsley, 3 it. 416; Farton?'. Prang, 3 it. 537; Cunningham r. Hall, i it. 43, Richardson v. Winsor, 3 12.395; L'nion Sugar Refinery v. Matthiesson, it. 639; Goodyear v. Beverly Rubber Co. i it. 348; Calendar r. Came, 4 it. 393.
A FIJIAN COURT DAY. BY ANDREW T. SIBBALD. THE natives of Fiji are amenable to a criminal code known as the Native Regulations. These are administered by two courts,—the District Court, which sits monthly and is presided over by a native magistrate, and the Provincial Court, which assembles every three months before the
English and native magistrates sitting to gether. From the latter there is no appeal except by petition to the governor, and it has become the resort of all Fijians who are in trouble or consider themselves aggrieved. The District Court assembles at ten o'clock a. in., and has to inquire into several charges
