EDITORIAL DEPARTMENT transaction shall cease to be interstate com merce and become the internal commerce of the state; both acts preserve the rights of the states, and at the same time dispose of the un seemly conflict theretofore existing. Under such a statute the right of a corporation to make contracts out of the state creating it — its interstate commercial transactions — could be preserved, and at the same time a uniform system of requirements could be provided under which citizens of the several states might be informed of the financial responsibility and legal character of the foreign corporations with whom they deal, and due service of pro cess might be had within the bounds of each state. Such regulations would of necessity restrict the powers now exercised by the states, but at the same time corporations now en gaged in interstate commerce would within certain limits be subjected to state laws. Neces sarily such regulations could not directly inter fere with the internal commerce of the states." HISTORY (The Supreme Court). In the February Yale Law Journal, George P. Costigan, Jr., writes of the history, functions, and methods of The Supreme Court of the United States (V. xvi, p. 259). INTERNATIONAL LAW. " The Third In ternational Conference of American States," by Paul S. Reinsh, American Political Science Review (V. i, p. 187). INTERNATIONAL LAW (Japanese Treaty). Simeon E. Baldwin writes in the Febru ary Columbia Law Review (V. vii, p. 85) on "Schooling Rights under Our Treaty with Japan." "The underlying question, it will be observed, is not, as things stand, whether the United States can by treaty virtually compel a State to educate resident foreigners. It is whether, if a State confers the privilege of full education on all residents, and allows every American child to go to such one of the public schbols as is at the most convenient distance from his place of residence, it can deny the same identical privilege to a Japanese child. The treaty is aimed against discrimi nation, and discrimination exists if any right ' whatever ' relating to residence is, either by the United States or by any State, given to an American and denied to a Japanese."
187
The main argument against this view unfavorable to California is that, by Article II, the treaty is not in any way to " affect the laws, ordinances, and regulations with regard to police and public security " of the United States or any of them. Mr. Baldwin considers it debatable whether this reserva tion of the police power does not author ize California to do precisely what it has done. INTERNATIONAL LAW (Congo Free State). The present agitation over the Congo Region renders timely the article by Hannis Taylor, in the American Law Review (V. xli, p. 102), on " The Congo Free State." He gives the history of its origin, and declares that " in view of the current reports as to conditions in the Congo State, it would seem to be within the province of the United States Government, as of any other power signatory to the Brussels Act, to suggest to the other signatories the importance of instituting an inquiry to deter mine (1 ) whether the government of the Congo State, by its permission of a revival and continu ance of conditions rivaling the worst ' crimes and devastations ' of the slave trade, is not in violation of the spirit and the letter of its engagements under the act of Brussels, and (2) whether the system of monopolization of territory and products maintained and enforced by the Congo Government is not itself directly and fatally hostile to a just discharge of the engagements contracted by the Congo Government in the act of Brussels, and thus fatal to the purpose of the powers as represented in that act. "It is well known that the agitation in England for some action by the government under its treaty obligations looking to reforms in the Congo has been as great, if not greater than in the United States, but England has apparently been loath to act, while there was a prospect that Belgium will annex the Free State. The matter of annexation is now before the Parliament at Brussels, and in the result of the debate there may be a solution of the entire difficulty. It seems that Great Britain, with whom this government is earnestly co-operating, will be satisfied if the govern ment of Belgium takes over control of the Congo, a result most likely to be reached.
