NOTES OF RECENT CASES ence or to some secret process. It is essential that before one can be enjoined he must know exactly what he is forbidden to do. In Taylor Iron and Steel Co. v. Nichols, 69 Atl. Rep. 186. the Court of Errors and Appeals of New Jersey held that the embodiment of the secret in the injunction is not necessary, but testimony taken in camera may be sealed, and used only when it becomes necessary to determine whether there has been a violation. HUSBAND AND WIFE. (Alienation of Hus band's Affection.) N. Y. Sup. Ct.— A youth of
1 8 years, without the knowledge of his parents, married a girl of the same age. They agreed to keep the marriage secret and not to live together until he attained the age of 2 1 . When the father of the boy learned of this arrangement he sought to discourage him from seeking the society of his wife. The boy was sent away and upon his return he was arrested on a charge by his wife of failure to support her. Thereupon he promised to live with and support her. He took her to a scantily furnished room in an apartment provided by his parent. At night he suggested that he retire to a back room and sleep with a cousin. To this she objected. They lay on the bed with out removing their clothes and talked all night. No provision had been made for food or for cook ing. The next morning the wife returned to her mother and the husband made no further effort to live with her. In Cochran v. Cochran, in New York Supplement. 588, a suit by the wife against the father of her husband for the alienation of his affection, the Supreme Court of New York held that this young woman had been exposed to the loss of her marital rights, the respect and confidence of her friends and associates, and the temptations always incident to these unfortunate complica tions and that a verdict of $7500 was not grossly excessive. INTOXICATING LIQUORS. (Locker-clubs.) U. S. Dist. Ct. Ga. — A most disgusting state of affairs is brought to the notice of the Grand Jury in the charge of the United States District Judge, 162 Federal Reporter, 736. It appears that socalled " locker-clubs " are conducted in Georgia by the permission of the municipality, under the theory that a tax by the state on these institu tions justifies the granting of a license. The statute provides that it shall not be lawful for any person within the limits of this state to sell or barter for valuable consideration, either directly or indirectly, any alcoholic, spirituous, malt, or intoxicating liquors. The club in question was conducted in a room about 16 by 16. All the bar fixtures were present. A white woman was serving liquor to a crowd of negroes, some of
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whom were seated in the corners in bibulous un consciousness. The only lockers were two or three small ones behind the bar. The Court, remarking that the law does not distinguish between the high and low estate of these locker-clubs, held that a municipal corporation cannot lawfully license or charter a club which in fact sells or furnishes liquors to its members and to them such illegal charter is no protection. Each one contributing to its support or maintenance is a retail liquor dealer within the internal revenue law, each being subject to a tax as such. INTOXICATING LIQUORS. (Revocation of License.) La. — Ordinances of New Orleans pro hibit the establishment of barrooms except upon written permission granted by the council, and provide that " no permit shall be granted to operate a barroom within 300 feet of a church or school," but that such places not having changed their identity since their establishment shall not be compelled to obtain permits. In Graziano v. City of New Orleans, 46 So. Rep. 566, it appeared that a barroom which had been operated prior to the establishment of a church 300 feet away had been rendered unfit for occu pancy by fire. The church, seeking to have the license revoked, protested that closing for repairs had changed its identity, that upon reopening it had not secured a written permit, and that it was situated within 300 feet of a church. An ordinance was passed annuling the license. From a judgment perpetually enjoining the enforcement of the ordinance defendant appealed. The Su preme Court of Louisiana holding the proposition that the identity of the building was changed by reason of the facts stated untenable, affirmed the judgment. INTOXICATING LIQUORS. (Owners of Real Estate.) Mass.— Petitioner in Moran v. Gallagher, 85 N. E. Rep. 579, sought to procure a license to sell intoxicating liquors to be drunk on the prem ises. The statute provides that an owner of real estate within 25 feet of the premises may object to the issuance of a license. The owner of real estate on the opposite side of the street was also the owner of the fee of the entire street in front of the property described in the appli cation for a license, subject to an easement of the public to use it for travel. The Supreme Judicial Court of Massachusetts held that the existence of such an easement leaves the owner of the fee with such a title as is necessary to constitute him an owner of the real estate within the meaning of the statute, and he may prevent the granting of a license. INTOXICATING LIQUORS. (What consti tutes a " Conviction " under License Law.) N. Y.
