UAFWIH
210
previously submitting it to the Parliament, an edict
granting to aU subjects the right of worshipping as
they pleased in their own homes. In July, 1561, he
caused all prosecutions for religious opinions to be sus-
pended imtil a *' council should be assembled. This
" council", which was the Colloquy of Poissy, resulted
in nothing. By another edict (15 January, 1562) he
granted to the Protestants liberty of worship outside
of cities, and recognized their right to hold meetings in
private houses, even within the limits of cities. This
edict the Protestants always regarded as a kind of
charter of enfranchisement, and during the religious
wars they constantly demanded its restoration.
But other measures touching the Church, taken by L'Hospital at the same time, gave the Holy See good reason for uneasiness. He caused a thesis on the pope ' to be denounced before the Parliament, because it seemed to him too ultramontane; he opposed the mon- itorium by which Pius IV had invited Jeanne d'Al- bret to appear in France before the Inouisition. At last Pius IV in 1562 requested of the French Court that the chancellor be dismissed. L'llospital, in fact, was not present at the conclusion of the.coimcil which decided on war against Cond^ and the Protestants; he returned to court only after this first war of religion, when the Edict of Amboise (19 March, 1503) restored religious peace by guaranteeing certain liberties to the Protestants. He agreed with Catharine de' Medici that the cause of peace would be served by having Charles IX declared of age, and by letting him make a progress through the country. The declaration of the king's majority took place m 1563, and from 1564 to 1566 L'Hospital caused him to make an extensive journey through France. During this tour the Ordi- nance ot Moulins (February, 1566) was promulgated b^ the chancellor, to reform the administration of jus- tice. But L'Hospital's plans failed; party violence continued, and the Catholics blamed him for his indul- gence towards the Protestants, all the more bitterly because he refused to let the Council of Trent be pub- lished in France. In February, 1504, he had declared himself so strongly against the acceptance of the Tri- dentine decrees that the Cardinal of Lorraine ex- claimed : *' You should take off your mask and embrace Protestantism." The same cardinal also, when he appeared before L'Hospital at Moulins (February, 1566) to demand the abrogation of the Edict of Am- boise, treated him as a worthless fellow {htlitre).
Meanwhile, suspicion of him continued to increase in the Catholic camp, and after the Protestants had made an attempt at Meaux (26-28 September, 1567) to get possession of the kind's person, thus precipitat- ing the second war of religion, Catharine ae' Medici turned against the chancellor with the brutal words: " It is you who have brought us to this pass with your counsels of moderation ". From that day the policy of moderation, which had been L'Hospital's clream, was exploded; his repeated assurances of Huguenot loyalty were belied by the conspiracy of Meaux, and he retired, disheartened, to his estate at Vignay. Ir- removable as chancellor, he had to give up the seals on 24 May, 1 568. He followed from a distance the events which little by little brought Catharine de' Medici to the Massacre of St. Bartholomew. His daughter, who was in Paris at the time of the massacre, was saved through the protection of Francois de Guise's widow. L'Hospital himself and his wife were threatened by the peasantry of Vignay, and a report was spread that they had been killed; Catharine sent some soldiers to protect him. On 1 February, 1573, the Court com- pelled L'Hospital to resign the chancellorship, and he died six weeks later. His Latin poems, which in the seventeenth centur>' had passed into the hands of Jan de Witt, grand pensionary of Holland, were published in 1732, in a more complete edition than that of his grandson (1585). His complete works, edited by l)ufey, appeared at Paris, in 1824, in five volumes.
VniUBiiAiN, Etudea tTHiaUnre modeme (2nd ad., Paris, 1850);
Amphoux, Michel dt VHdpilal el la Ubert^ de conecienee au
XM' eUde (Paris. 1900); Atkinson, Michel de L'HoepHal
(London, 19€k)); Dupr^Lasalb, Miaiel de VHu^jntal avarU
eon iUvation au posle de chancelier de France (2 vols., Paris, 1S75-
1899); Shaw, Michel de VHoepital and Hie Policy (London.
1905).
Georges Gotau. Liafwin (Liefwin), Saint. See Lebwin, Saint. Liao-tnng. See Manchuria.
Libel (Lat. libeUuSf a little book), a malicious pub- lication by writing, printing, picture, effigy, sign, or otherwise than by mere speech, which exposes anv living person, or the memory of any person deceasea, to hatred, contempt, ridicule, or obloquy, or which causes or tends to cause any person to be ashamed or avoided, or which has a tenclency to injure any per- son, corporation, or association of persons, in his, ner, or its business or occupation. The use of the wonl libel, as relating to defamatory WTitings, seems to have originated early in the sixteenth century. Such a writing then became known as a libellus famosuSf i. e., a scurrilous or defamatory pamphlet. Since the ear- liest ages every civilized community has provided for the protection of the citizen from defamation of char- acter, and practically the same theories of redress and penalties as exist to-dajr were held under the very ancient laws. The Mosaic law provided penalties for the offence (Ex., xxiii), and under the laws of Solon it was punished by a severe fine. A libel may be either a civil injury or a criminal offence. The theory upon which it IS made the subject of criminal law is that it is calculated to cause a breach of the public peace. Libel differs essentially from slander, in that it may be the subject of both criminal and civil litigation, whereas slander is not a criminal offence.
Many statements may be actionable per se when ^Tittcn or printed, and published, which would not be actionable if merely spoken, without claiming and proving special damage. Thus, unwritten words im- puting immoral conduct are not actionable per 96 unless the misconduct imputed amounts to a cnminal offence, for which the person slandered may be in- dicted. If the published matter holds a person up to public scorn, contempt, and ridicule, it is libellous per se. Libel per se embraces all cases which would be actionable if made orally, and also embraces all other cases where the additional gravity imparted to Uie charge bv the publication can fairly be supposed to make it damaging. The nature of the charge must be such that the court can legally presume that the plain- tiff has been degraded in the estimation of his acquain- tances or of the public, or has suffered some loss, either to his property, character, or business, or in nis do- mestic or social relations, in consequence of the publi- cation of such charges. Ck)mpensation for mentuU suffering caused bv the libel may be included in the damages recovered. In cases of libels upon the dead, although no private injury in the ordinary sense re- sults to anyon^, they are properly the subject of crim- inal prosecution, as being likely to cause a breach of the peace, on accoimt of the resentment of the surviv- ing relatives.
In criminal prosecution in Great Britain, and in many jurisdictions in America, for many years the lury have been made judges of both the Law and the fact (Fox's Criminal Libel Act, 32 George III, c. 60). In such cases it is still the duty of the presiding rfidg/i to inform and instruct the jury as to the law of evi- dence, and to decide all questions arising in that re- gard.
The law of libel is not limited to injuries done^ to personal reputation, but also includes the protection of the reputation of property; and this form of libel is common ly called slander of tit le. Slander of title wbs actionable at common law upon proof of special dam- age. A claim of title made in good faith, however*
