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Latest Important Cases Central & Hudson River Railroad Co. The Court held that corporations are on a par with natural persons and may be dealt with by inferior courts upon complaints for offenses within their jurisdiction. The Court declared that the trend of recent legal authorities has been to make corpora tions like individuals amenable to trial by criminal complaints where they cover the ofienses charged. The district court had jurisdiction by virtue of the general provis sions of Revised Laws, chap. 160, sec. 24, giving it the right to deal with "all crimes and ofienses” less than felony, “except libels and conspiracies." Criminal Law. cedure.

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Corporations,

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709

colored men being excluded; and the same might be the result, in some localities, of an educational test; and it could not be said, although that was the result intended, that it was a discrimination on account of race or color, but it would be referable to a difi'erent test. But looking at the constitution and laws of Maryland prior to January 1, 1869, how can it be said with any show of reason that any but the white man could vote then —and how can the Court close its eyes to the obvious fact that it is for that reason solely that the test is inserted in the Maryland Acts of 1908? And is not the Court to take notice of the fact that during all the forty years since the adoption of the Fifteenth Amend ment, colored men had been allowed to

register and vote in Maryland until the enact Equity.

See Conveyances.

ment of the Maryland statute of 1908?"

Fifteenth Amendment. violated by Maryland Statute of 1908—‘ ‘ Grandfather Clause." U. S.

Federal Circuit Court in Oklahoma De clines ]urisdiction—“Grandfather Clause" in State Constitution. Okla.

All devices in use in the South for the pur pose of wiping out the colored vote were declared unconstitutional by Judge Thomas J. Morris, of the United States Circuit Court

Holding that it had no jurisdiction to grant relief from the operations of the "grand father clause" amendment to the Oklahoma constitution, the federal circuit court at Guthrie, Okla., on Nov. 1 dismissed the appli cation of Daniel Sims, a former slave, who asked a writ of injunction that would permit him and other negroes to vote at the general election on Nov. 8. This decision made the grandfather clause operative for the recent election disfranchising several thou sand negroes. An appeal has been taken.

in the Anderson Case, lately decided at Balti

more. The original action which was brought against the Annapolis registers was based on their refusal to register three colored men because they could not comply with the provision which required them to have been able to vote in 1868, or if not then, that their ancestors must have been eligible to vote.

Anderson, one of the colored men,

could not have voted at that time because of his race and color, and Howard and Brown, two others, were denied registration because their father and grandfather, respectively, could not, on account of race and color. have so voted. The Court said :— "It is true that the words ‘race’ and ‘color’ are not used in the statutes of Maryland, but the meaning of the law is as plain as if the very words had been made use of; and it is the meaning, intention and effect of the law, and not its phraseology, which is im portant. . . .

"There are restrictions to the light of voting which might, in fact, operate to exclude all colored men which would not be open to objections of discriminating on account of race or color. As, for instance, it is possible that a property qualification might, in fact, result in some localities, in all

Insurance. Mortgagee Clause in New York Fire Insurance Policy— Notice of Loss by Mortgagee. N. Y. An interesting decision relating to the New York Standard Form Fire Insurance Policy and the usual mortgagee clause was recently handed down by the New York Appellate Division in the case of Heilbrun v. German Alliance Insurance Co. (reported N. Y. Law journal Nov. 14, 1910). The policy contained the usual mortgagee clause, and the plaintiff was assignee of the mortgagee. There was no allegation in the complaint that the required notice of loss and sworn proofs 01 loss were ever given to the insurance company,

either

by

the

assured

or

the

mortgagee, or this assignee plaintiff. The defendant demurred to the complaint because of the absence of such allegation. It was held that "the mortgagee was under no obligation to furnish proof of loss or to give