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accommodation," must be regarded as limited and the searchers as to what he had been informed qualified by the specific designation of "inns, as to the breeding and training of the dogs, and restaurants, hotels, eating-houses, bathhouses, that an old schoolmate of his had highly indorsed barber shops, theaters, music halls, and public them in a letter, as well as testimony of a witness conveyances on land and water," which precede that he had looked up the history of the dogs and believed them trained for great capacity for it. The cases of People v. Richards, 108 N. Y. 137, following and tracking, and testimony by him 15 N. E. 371, a Am. St. Rep. 373; People v. N. Y. as to stories he had heard about the ability of & Manh. Beach Ry. Co., 103 N. Y. 472, 479, the dogs, was erroneously admitted. In a nearly 9 N. Y. 605; Matter of Hermance, 71 N. Y. 481; contemporaneous case from the Supreme Court Mangam v. City of Brooklyn, 98 N. Y. 585, 595, of Nebraska (Brott v. State, 97 N. W. 593), that court holds that in a criminal prosecution, evi 50 Am. Rep. 705, are cited in support of this prop osition. It is admitted that a boot-blacking dence that bloodhounds went from the scene of the crime to defendant's house, is not admissible. stand may be said to be a place of public accom modation like the store of a dry-goods merchant, In the Kentucky case, it was shown that great a grocer, or the proverbial "butcher, baker, and care was taken to prevent anyone from going candlestickmaker," but that is very far from to or about the place of the crime until after placing it in the same category with the places the bloodhounds were brought there, and that specifically named in the statute. "There is," the dogs went immediately to the house occupied says the court, "a superficial resemblance between by defendant, went up to him and stopped. The the occupation of the barber and that of the owner of the dogs testified as to their age, and boot-black, in the sense that both minister to that both were bloodhounds of good breeding, the personal comfort and convenience of others, the sire of the older one being a pure bloodhound, but the same argument could be extended far and the grandsire an English bloodhound, trained beyond the limits necessary to demonstrate that in tracking men. It was further testified by not all other places of public accommodation are their owner that both dogs had been carefully included by relation within the category of the trained in tracking men, and that the older dog things specifically enumerated in the statute. had tracked and aided in the capture of sixtyThe legislature seems to have had no difficulty three criminals, in several of which cases the in naming a variety of places and callings that younger dog had assisted. On this evidence, have never been regarded as 'places of public the court holds that while the pedigrees of the accommodation' under the common law, and dogs were not asked about or stated with par if boot-blacking stands are to be brought within ticularity, the testimony was sufficient to show the purview of the statute under the words, 'and that they possessed the breeding, qualities, and all other places of public accommodation,' it will training required by the rule formerly announced require no great stretch of the imagination to apply by the court in Pcdigo v. Commonwealth, loj this statute to innumerable places and callings Kentucky, 41, 44 Southwestern, 143. that have never been and probably never will be regarded as subject to legislative control or direction." EMINENT DOMAIN. (VALUE OP PROPERTY) SUPREME COURT OF ILLINOIS. A novel ground for increase of damages in CRIMINAL LAW. (EVIDENCE — ACTION OF condemnation proceedings is put forward by BLOODHOUNDS) defendant in Dowie v. Chicago, W. & N. S. Ry. SUPREME COURT OP KENTUCKY. Co., 73 Northeastern Reporter, 354. The rail Another contribution to the growing list of road company commenced proceedings to obtain cases involving the question of the admissibility, a right of way over land included within thein prosecutions for crime, of evidence of the limits of Zion City, and defendant Dowie claimed actions of bloodhounds in tracking the supposed that the land sought to be taken comprised criminal, is the case of Denham v. Commonwealth, between seventeen and eighteen acres, worth 84 Southwestern Reporter, 538. The Iowa case $221,000, and that adjacent lands not taken of McClurg v. Brenton, 98 Northwestern Reporter, would be damaged in the sum of $100,000. The 881, referred to in these notes some time ago, land sought to be taken was unimproved, and held that in a civil action for trespass by one similar land lying adjacent to it could be obtained whose premises had been searched at night by in practically unlimited quantities for from, persons led there by bloodhounds, attempting $100 to $200 per acre. Defendant and his wit to follow a chicken thief, testimony by one of nesses, who were members of his church, testified
