United States to adopt a common ratio between gold and silver, and provided for the appointment of commissioners for that purpose. An act with similar object was subsequently enacted, as noted elsewhere. This act further authorized the issuance of silver certificates for $10 or more, to be given in exchange for a like amount of silver coin, which should be retained in the treasury for payment of the certificates on demand. By the act of June 19, of the same year, the secretary of the treasury was authorized to use coin certificates for payment of depositors of bullion at the several mints and assay offices.

The issuance of silver certificates of one, two and five dollars was authorized by the act of August 4, 1886.

The law authorizing the coinage of the trade dollar was repealed by the act of February 19, 1887. A period of six months after the passage of the act was allowed, however, during which they would be received and standard silver dollars or subsidiary coins of equal value given in exchange therefor. The trade dollars so received were then to be recoined into standard silver dollars or subsidiary coins.

The act of July 14, 1890, generally know as the Sherman law, directed the purchase by the secretary of the treasury of silver bullion to an amount not exceeding 4,500,000 ounces per month, at the market value, providing it did not exceed $1.00 for every 371 grains, the amount of pure silver contained in a standard silver dollar. In payment therefor treasury notes were directed to be issued, in denominations of $1.00 to $1000.00, which were to be redeemable in coin, on demand, after which they might be reissued. But no greater or less amount of such notes were to be outstanding than the cost of the bullion and the standard silver dollars coined therefrom then held in the treasury, purchased by such notes. It was further directed that 2,000,000 ounces of silver bullion so purchased be coined each month into standard silver dollars until July 1, 1891, and there after as much as might be necessary for the redemption of the treasury notes provided for by the act.

The act provided further that the fund for the redemption of circulating notes of national banks be covered into the treasury, and that their redemption be thereafter made from the general fund. This provision, however, was not to apply to the deposit required by the act of 1874 of every national bank of an amount equal to five per cent. of its circulation. The conflicting portions of the act of 1874 were also expressly repealed.

In August, 1893, a special session of Congress was called, and on August 11, Mr. Wilson of West Virginia introduced a bill to discontinue the purchase of silver bullion as provided by the Sherman law. After a long debate, and the proposal of several amendments, the amendment attached by the senate was agreed upon, passed by both houses, approved by the President, and became the act of November 1, 1893.

This act declared it to be the policy of the United States to continue the use of both gold and silver as standard money and to maintain the parity of the two metals. It concludes as follow: "And it is hereby further declared that the efforts of the government should be steadily directed to the establishment of such a safe system of bimetallism as will maintain at all times the equal power of every dollar coined or issued by the United States in the markets and in the payment of debts."

A considerable portion of the time of the Fifty-third Congress was consumed in the consideration of the Bland Seigniorage Bill and other measures of similar character; but of those proposed measures nothing will be said, it being the purpose of this article to consider only those acts which have become enrolled upon the statute books.

With this number the MICHIGAN LAW JOURNAL presents a sketch of the life of James F. Joy. He is so well known both here and elsewhere that an article with him for the subject must contain matter which does not concern itself so much with the part he has taken in aiding the progress and advancement of this section of our country-that is already very well known-but rather dwelling on his antecedents and the character which has brought about his

success.

We shall hope to present in the future sketches of other prominent men, more especially prominent lawyers and judges of this state. We trust that this feature of the MICHIGAN LAW JOURNAL will prove of interest to our readers.

Discussed so thoroughly as the Venezuelan controversy has been by the press of the countries concerned, little can be added to the literature on the subject, but the MICHIGAN LAW JOURNAL Would like to know one thing concerning the president's message to congress: How much of it, was politics and how much was real feeling? The enforcement of the Monroe Doctrine has been a safeguard in the past not alone in the weaker nations of the new world but to the United States itself. The independence of Mexico has been insured by it and our southern border protected from the control of a powerful European nation. The president's message, however intended, has been received with very remarkable and unusual sympathy from the people of the United States. He has reiterated a doctrine always popular and almost vital. The independence of the new world from European control is essential and must be maintained. And yet, was the president's message something which he is ready to stand or fall by?

The nomination of Rufus W. Peckham by President Cleveland to the position of Justice of the Supreme Court, and his confirmation, has met with the unqualified approval of the bar of the country.

The Bar Association of Detroit recently held a meeting and appointed a committee to consider the revision and change of certain court rules and to propose modifications of statutes regulating the joinder of parties in suits in assumpsit. Mr. James H. Pound was chairman. His view of the joinder of parties is to permit of amendment in the declaration in cases of non-joinder or mis-joinder of parties in suits on contract. This is a move and an important one, under certain restrictions, to the growth and advancement of the the law.

Since our last issue Harry Hayward has paid the extreme penalty of the law for the crime of murder. Here was a character remarkable in these times of remarkable characters. He has long been a past-master in all kinds of wickedness, vice and crime. His passion for gambling was the key and controlling trait in his char acter. Starting with a love of ease and the ability to indulge in it, which the possession of money insured, games of chance quickly followed on failing fortunes. The last hope of some men when money, and what money buys begins to fail is not that slow but sure cure for poverty, work, but the begetter of worse fortune-chance. A man who is failing financially and who has gambled even moderately, looks almost unconsciously to blind chance-luck—as a cure. That was Hayward's remedy. He had a good social position, and possessed more than average ability, but his love of self-indulgence was his first step to ruin; gambling once a pastime became a necessity; he must win whoever lost. Whatever suffering was entailed on others, gambling and success in it meant everything to him. It was the best school in the world to inculcate selfishness and to eliminate conscience. He learned well the lesson, and all the better from the fact that he did not exercise his conscience. The arm that is not used wastes away; the conscience that is not exercised fails. This thought is an attempt at explaining how Hayward with his abilities and advantages could fall so low and fail so utterly in realizing the hopes and, ambitions which once swayed him. He was a moral degenerate of a remarkable type and his character is worthy the critical study of a Nordau or a Lombroso.

The recent supreme court decision confirming the authority of the board of estimates of the City of Detroit to control and limit the disbursements made by the common council to the amounts and for the purposes for which the moneys are raised by taxation, is a very

salutary check upon the ordinary methods and tendencies of municipal expenditure.

Prior to the enactment of the law of 1895, the power of the board was at least ambiguous. It seemed reasonable to suppose that moneys raised by taxation, should be devoted to the purposes for which they were raised, and while this was done in the main, nevertheless such was not the interpretation of the common council, which took the liberty to depart from the principle in almost any way it saw fit, and there appeared to be no way to enforce a proper construction. Items and amounts were explicitly disallowed by the board, and the council would have no hesitancy in making use for such items of funds which were appropriated for other purposes. were exhausted the council, contrary to the express provisions of the charter, would borrow or authorize the controller to borrow money to restore the drains on the fund. The next year there would be included in the budget items to pay back these loans, thus taxing the people to pay debts unlawfully contracted and utterly illegal.

In one of these instances where the board of estimates were asked to approve of an item of $60,000.00 to repay an illegal loan, the board took occasion to file a protest with the controller and council, and notified them that in the future the board would not allow such items. The warning was signed by 32 out of 37 estimators, some being absent from the city. An effort was made by the council in the case of allowing extra funds to a poor commission to force the board of estimates to back water on their position, but failed.

Shortly after Estimator Robinson, who had been largely instrumental in bringing about this result, conferred with Geo. W. Pardridge, formerly on the board of estimates, but at this time a member of the State Legislature from Detroit, and a law was drafted with the approval of the local municipal charter committee, amending the charter power of the board of estimates and enlarging its authority in the manner desired. The bill was warmly supported by most of the Detroit members. The council protested against its passage, and some opposition was raised to defeat it, but without

success.

The vital portion of the act as passed is this provision:-"The said board shall have the power and it shall be its duty, after careful consideration of the various estimates referred to it, if it shall deem it advisable so to do, to disallow any item, items, or parts of items, in the different funds, as well as in the gross amounts thereof, as the said board may deem advisable, and it shall be unlawful for the common council of said city to create any expenditure or expend any moneys as to items specifically disallowed and disapproved by such board of estimates."

Notwithstanding this law the council utterly ignored and disobeyed it. Thereupon Messrs. James B. McKay, Bethune Duffield and Fred. A. Robinson, the latter as attorneys on behalf of the three