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THE GREEN BAG a few states, though generally rendered un necessary by local statutes. The rule that title to land in adverse possession can not be conveyed by deed, which arose by virtue of the common law against maintenance and assignment of causes of action, and by virtue of the statute of 32 Hen. 8, c. 9, known as the pretended title-act, is still the law in several states, though abolished in many. The com mon law as to capacity of parties in large part remains. Other common-law essentials to a valid transfer of lands by deed may still pos- . sibly exist. But in the main, our conveyances by deed are purely matters of local statute and usage." The following conclusions may be drawn from the foregoing discussion: "i. That the statute of uses, the doctrines concerning uses, and conveyances operating by virtue of the statute of uses, have little or nothing to do with the validity of the ordinary conveyance in the great majority of the states. It must be remembered that we are not discussing the importance of the old law to enable one to understand, or as still governing, trusts, whether created by deed or otherwise. "2. That generally a conveyance satisfying the local statutes is sufficient, and one not satisfying such statutes is insufficient, regard less of the old common law. "3. That in about a fifth of the states one or more of these old conveyances at common law and under the statute of uses, are still retained in modified form and effect by the local statutes. "4. They may still have effect in a few states regardless of or notwithstanding the State statutes." PROPERTY (Torrens Law). "Reform of Our Land Laws " an address before the Vir ginia Bar Association by Eugene C. Massie in the November-December number of the American Law Review (V. xxxix, p. 871) 1 also previously printed in the Virginia Law Register for September, advocates the pas sage of a bill by the Virginia legislature estab lishing a Court of Land Registration under the Torrens System, so that real property ma}' be made easily transferable and thus dealt in as readily as other property, and so that the method of sale of land to pay taxes may be

improved. The decisions of the Supreme Court of the United States which are fully considered by the author, uphold the consti tutionality of such a system. PUBLIC POLICY (Railroad Rates). The attack by opponents of Congressional rate regulation upon the constitutional power of Congress is deprecated by David Walter Brown in an article in the December Columbia Law Review (V. v, p. 600) entitled " A Dangerous Position for the Railroads." He presents the unanswerable syllogism that regulation of rates is inherent in the sovereignty of the body politic, that if it has not been granted to Congress it remains in the states, and that the alternative to Congressional regulation is a multiplicity of State regulations which the railroads would like even less. PUBLIC POLICY. " State Insurance of Lives," by Talcott H. Russell, The Law (V. i- P- 395)PUBLIC POLICY (See Corporations, Con stitutional Law, and Diplomacy). TORTS. " The Legal Right of Automobile Drivers upon the Public Streets and High ways," by Sumner Kenner, Central Law Jour nal (V. Ixi, p. 464). TORTS (Negligence). "The Doctrines of Assumed Risk and Contributory Negligence as Defenses to Actions for Damage Resulting from a Failure to Comply with Express Statu tory Provisions," by M. C. Freerks, Central Law Journal (V. Ixi, p. 446). WILLS (Equitable Conversion). Previous to3 and 4. Win. 4, c 104 land of a deceased per son was not liable for his debts, and it seemssurprising that courts should have held that the conversion of money into land by will enabled a testator to deprive his contract creditors of their right to be paid. These cases, however, seem not to be upheld by the authorities. Taking up the question of contracts, theauthor states that it is desirable to enlarge upon his statement in a previous article, that a bilateral contract for purchase and sale of land is the only species of contract in which an agreement to buy or sell land is alone suffi cient to create an equitable conversion, and furnishes the only instance of an equitable conversion which is always co-extensive with