Proportional Representation Held Unconstitutional in Kalamazoo.-Judge Jesse H. Root, of Monroe, Michigan, in a case brought before him in the circuit court for the county of Kalamazoo, has rendered a decision declaring unconstitutional the provision in the charter of the city of Kalamazoo providing for the election of city commissioners by the Hare system of proportional representation. The provision was attacked on the ground that it conflicted with the requirement of the constitution that "in all elections every inhabitant of this state shall be an elector and entitled to vote." The court held that this constitutional requirement was interpreted by the supreme court of the state in the case of Maynard v. Board of Canvassers1 as giving to each elector the right to vote for every officer to be elected, whereas under the Hare system, as applied to Kalamazoo, each elector is permitted to vote for only one of the seven commissioners to be elected. Judge Root also quotes the supreme court of Ohio-in which state the constitution then provided that each elector "shall be entitled to vote at all elections," a provision substantially the same as the Michigan clause as thus interpreting the case of Maynard v. Board of Canvassers in support of a decision that the Ohio clause guarantees to each elector the right to vote for each officer whose election is submitted to the electors.

Judge Root's decision takes recognition of the contention that these decisions have no applicability to the Kalamazoo case for the reason that city officers are not constitutional officers; that the opinions quoted from are all in reference to constitutional officers; and that the manner of electing city officers is purely a matter of local

concern. Judge Root disposes of this point on the grounds that however true it might otherwise be, it is entirely offset by the constitutional prohibition that "no city or village shall have the right to abridge the right of elective franchise."

On the other hand, Judge Root holds that the Kalamazoo charter is not void because it provides for the election of the mayor by a vote of the commissioners instead of by the people themselves. He also dismisses as purely typographical or clerical an error in the repealing clause of the charter, ruling that the undoubted intention of the charter framers, rather than its literal interpretation, should govern. Furthermore, he dismisses the contention that the court should refuse to enter a judgment of ouster because it would be futile, the respondents having been succeeded by a new commission (also elected by proportional representation), his position being that the proceeding was brought to test the constitutionality of the charter rather than the right of one man to hold office under it.

Judge Root's rather sensational decision seems to give general satisfaction among the opponents of proportional representation, and general dissatisfaction among its adherents-as might be expected. Pending an appeal to the supreme court, the city attorney has advised the commission to play safe, and, in matters of taxation, not to exceed the tax limit set by the old charter. The budget for 1920 is accordingly to be reduced so as to keep within the old charter limit of 10 mills. A charter amendment is also proposed, deleting the objectionable proportional representation clause and substituting the old majority system. Such action will require two special elections, one for a referendum on the charter amendment, and another for the election of new commissioners.

Exit "The Public," Enter "Taxation."-The announcement that The Public would cease to exist after its issue of December 6, 1919, came to many of its readers rather as a shock. Under the editorship of Louis F. Post, The Public achieved a well-deserved reputation for high, straight thinking, and was frequently referred to as the best-edited periodical in the United 184 Mich. 228.

State v. Constantine, 42 Ohio 537.

States. Upon the retirement of Mr. Post, Stoughton Cooley became its editor, maintaining in an able manner the standards which his predecessor had set. That the circle of The Public's readers was never relatively large is regrettable, but more or less in the nature of a distinction, since no serious review in America has ever appealed to more than an infinitesimal

Bellas v. Burr, 78 Mich. 1. Menton v. Cook, 147 Mich. 540.

part of our citizenship—and possibly never will. But that this circle should dwindle to a point where it could not sustain existence is, indeed, a tragedy in American journalism.

Simultaneously with the extinction of The Public came the announcement of a new magazine, Taxation, to be inaugurated in January, with James R. Brown, president of the Manhattan single tax club, as publisher, and Mr. Cooley as editor. Taxation is projected as an educational weapon for the business man and student of affairs that "will be devoted to the great underlying causes of social unrest and industrial maladjustment." It promises to be non-partisan, and to analyze the rights of the citizen and the proper sphere of government.

Citizens' Research Institute of Canada.— This institute, recently organized, is a dominionwide association of citizens to obtain and make available the fact basis of the administration of public affairs in Canada. The institute will harmonize its work with that of local bureaus of municipal research and similar bodies, and give wide circulation to such local material as is of general interest. The institute will endeavor, as one of its specific aims, to promote the movement toward the standardization of municipal, provincial and national accounting, which would, among other things, make possible the trustworthy comparison of statistics. Toward this end a series of pamphlets is being published on the cost of government in Canada.

A Civic Classification Scheme.-The municipal reference bureau of the University of Minnesota, of which E. L. Bennett is secretary,

has issued a "Classification Scheme for Material in the Municipal Reference Bureau," which represents a very careful and painstaking effort, and should prove of interest and practical value to all institutions concerned with the collection of municipal and civic data. Mr. Bennett's scheme includes some eighteen main subject heads, with appropriate sub-heads and sub-subheads. The main subjects are: municipal government; people's part in government; municipal corporations; forms of municipal government; municipal legislation; courts; administration; stores and purchasing department; finance; public safety; public health; welfare; city planning; public works; ports and terminals; public utilities; education, and civic organizations.

New Year Greetings from the City of Flint (Michigan) are contained in an attractive new year's card carrying the city's greetings on the front cover, a plan of the city on the inside, and on the back a quotation from Charles W. Eliot relative to city planning.

A Study of the Teaching of Government in secondary schools will be made by Professor Edgar Dawson of Hunter College, New York City, who has been given a year's leave of absence for the purpose. Professor Dawson, who is also field representative on civic education for the National Municipal League, will welcome correspondence with those interested in the subject, suggestions as to points which should be covered, or information as to successful experiments now being made in the field. It is expected that the results of this study will be published in the spring of 1921.