NOTES. New Hampshire, 16 South Dakota, I New Jersey, 22 Tennessee, 5 New York, 189 Texas, 9 North Carolina, 3 Utah, 3 North Dakota, I Vermont, 4 Ohio, 74 Virginia, 4 Oregon, 4 Washington, 7 Pennsylvania, 48 West Virginia, 3 Rhode Island, 21 Wisconsin, 10 South Carolina, I British Columbia, 2 139 Cape Breton Island, i New Brunswick, 20 Nova Scotia, 10 U. S. of Colombia, 1 Austria, i Japan, 2 Harv'd Law School, 79 ^519 The membership roll comprises the names of nearly one-half of the whole number of former students of the Harvard Law School, known to be living, and includes representatives from the classes of 1825, 1829, and from every class from 1831 to the present time. The following table shows the growth in membership of the Asso- ciation since the publication of the first regular report by the Council on April i, 1887 : — April I, 1887, total membership . . , 560 January I, 1888, " ... 642 January i, 1889, ** <* ... 822 January i, 1890, ** ... 963 September 15, 1890, ** . . .1,519 Notice to Third- Year Men. — The Harvard Law School Asso- ciation offers a prize of one hundred dollars for the best essay on any of the following subjects : — I. Rights and Remedies of Minorities in Political and Civil Corpo- rations. II. Constructive Trusts arising out of Fiduciary Relations. III. Judicial Legislation : its legitimate function, if any, in the de- velopment of the Common Law. Competition for the prize is open to members of the third-year class, only. Competitors are requested to limit their essay to 50 pages of manuscript, the usual legal quarto size. The essays must be sent to the Secretary of the Association, 220 Devonshire street, Boston, Mass., on or before April 15, 1891. The prize will be awarded at the meeting of the Association which is to be held in Cambridge, in June, 1891. Louis D. Brandeis, Secretary. Among the many recent articles on the subject of marriage is an interesting paper on " The Cause of the Increase of Divorce," by Mr. Sydney G. Fisher, of the Philadelphia bar, formerly a member of the Harvard Law School. He calls attention to the fact that while in most of the States at the beginning of the century the laws allowed substantially the same freedom of divorce as at present, it is only very recently that people have begun, to any great extent, to take advantage of these laws. It is an error therefore to attribute the increase in divorce to changes in the law. To say that the cause is a change In public opinion, Is but truism. Mr. Fisher, therefore, proceeds to examine the origin and growth of public opinion. He finds that the theory of indissoluble marriage has been handed down from the mid- dle ages; he examines in some detail the cases in the Ecclesiastical
