CALVO AND THE " CALVO DOCTRINE" has often been the fact, but if so the trouble has been one of fact rather than one of law. The remedy would appear to be for Latin-American peoples to make sure that the facts are on their side, rather than shelter themselves behind legal principles, the validity of which is doubtful. Another application of the wider "Calvo Doctrine" is that a country is not liable for damages suffered by aliens in time of riots or insurrections. In this bald form, and it is in this form that Calvo puts it, it is not likely to find general acceptance. While a government is not liable for acts of insurgents who have attained the dignity of belligerents any more than for the acts of an enemy whose sovereignty is unques tioned, yet in suppressing an insurrection which has not yet reached the stage of legal war, it does not seem unfair to set up certain international standards as to the care necessary to be taken by the titular govern ment in protecting persons and property from the acts of the insurgents, and if the titular government does not live up to such standards, to hold it responsible for damage resulting to aliens in consequence, even though it make no compensation to its own subjects for similar injuries. Of course it is impossible to lay down very definite general rules as to when a government does fail in its international duty in a case of this kind, but as, in general, it is extremely difficult to lay down a rule to fit all cases, but in a par ticular case not difficult to see that the rule applies, so here it is almost impossible to say what the international standard is, but often not difficult to see that some gov ernment has not lived up to it. Again the question whether as a matter of fact European governments have treated LatinAmericans so unjustly as Calvo and SpanishAmericans claim would appear to be rather a question of fact than of law. Demands for indemnity in such cases have been ap parently less frequent in the relations of European countries among themselves than in their relations with Latin -American coun
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tries, and accordingly it has seemed to LatinAmericans that a different rule of law were being applied by Europeans towards them than that employed among themselves, but again it would seem unjustly. Whether as a matter of fact Latin-American countries have been treated unjustly, whether as a matter of fact their weakness has been taken advantage of by the stronger powers of the old world would require too intimate a knowledge of Latin-American history for the writer to express an opinion on. From the "Calvo Doctrine" we now turn. to Calvo himself. Carlos Calvo was born at Buenos Ayres in 1824. In 1852 he was made vice-consul at Montevideo and was consul-general and diplomatic representa tive of Buenos Ayres there from 1853 to 1858. In 1859 he was a deputy of the lower house and from 1860 to 1864 repre sented Paraguay as charge1 d'affaires at Paris, being also accredited to Great Britain. He was the official delegate to the geographi cal congress which met in Paris in 1878, and plenipotentiary to the postal congresses of Paris in 1878, and of Vienna in 1891. In 1883 he was accredited as Envoy Extraor dinary and Minister Plenipotentiary to Berlin, and in addition was accredited to the Russian Emperor in 1889, and to the Austrian Emperor in 1890. In 1899 he was transferred from Berlin to Paris, being accredited both to France and to the Holy See. He was one of the original members of the Institute of International Law, founded in 1873, and was made a correspondent of the Institute of France in 1869, and a foreign associate of the same in 1892. He also received numerous decorations. He died in Paris, May 2, 1906, where funeral services were held in the church of Saint-Pierre de Chaillot, preliminary to his removal and burial at Buenos Avres. His principal works are a collection of Latin-American State Papers, his annals of the Latin-American Revolution, his Manual of International Law for the use of students first published in 1881, his examination of
