prisingly good likenesses, and are all well executed. They comprise the greatest of living and dead law yers and judges of past and present times. We have thought them worthy of framing and hanging up in our office, and cordially recommend others to do likewise. Very likely, in these "stringent" times, the publishers would not object to the purchaser's "hanging up " the payment for a reasonable period.
A CORRECTION. — A mistake, which the Easy Chair very much regrets, crept (they always "creep," never seem able to go upright) into its account of the late conference at Milwaukee of the States Com missions on Uniform Legislation. It was stated that Mississippi was not represented there. On the con trary, two of the commissioners from that State were present, — Mr. Thompson, who travelled nine hun dred miles, and Mr. Sullivan, who travelled seven hundred miles, both at their own expense. We hope these gentlemen will accept our apology for the error, which of course was inadvertent, but never theless very careless. It is to be hoped that Missis sippi, and the other States which do not pay even the expenses of their commissioners, will see the fairness of doing so.
NOTES OF CASES. POLYPHEMUS' TWIN. — Under the head ot " The Case of Polyphemus " we recently discoursed in this department of Bawden v. Liverpool, etc., Assurance Co., 2 Q. B. Div. (1892) 534; 46 Alb. L. J. 390, the case of the one-eyed man insured against accident producing "complete and irrevocable loss of sight in one eye " or " to both eyes," in which it was held that he might recover as for the loss of sight of both eyes upon the loss of sight of his only eye. Now we discover that this was anticipated in Pennsylvania, in 1891, in Humphreys v. Nat. Ben. Ass'n, il Lawy. Rep. Ann. 564. The facts were precisely the same in both cases, except that in the latter the policy did not provide for loss of one eye, but only for " total and permanent loss of sight of both eyes; " and it was held that the Cyclopean plaintiff might recover there for upon the loss of his single eye. The court said : — "The loss of one eye to him was precisely the same as the loss of both eyes by an ordinary man. It is total blindness in either case. There is no provision in the policy for the loss of one eye, as there is for the loss of one arm or one leg. The reason is plain. The loss of one eye does not produce a ' total and permanent loss of sight.' For all practical purposes a man with one eye can still follow his occupation and gain his living, while the loss of an arm or leg is a disability which seriously inter
feres with his ability to earn his bread; hence it was that the policy provided, or rather defined, the ' loss of sight ' as the Moss of both eyes.' It was the loss of sight which was insured against; and this was just as complete in the plaintiff's case as though both eyes had been lost during the life of the policy. Assuming that the company in tended to insure the plaintiff against something, and that that something was the loss of his sight, the most that can be said is that having but one eye the risk was increased : but the risk was not increased after the policy was issued. "It is reasonable that the parties did not intend the policy to cover the matter of eyesight at all? Yet this is the conclusion we must come to, if we sustain the defend ant's contention. Where the terms of a policy are sus ceptible, without violence, of two interpretations, that construction which is most favorable to the insured, in order to indemnify him against loss sustained, should be adopted. Teutonia F. Ins. Co. v. Mund, 102 Penn. St. 89; Burkhard v. Travelers' Ins Co., id. 262." This is a striking proof that there is no case so queer that another just about like it does not turn up about the same time. VOLENTI NON FIT. — In Fitzgerald v. Connecticut River Paper Co., 155 Mass. 155, it was held that a female employee in a mill the steps of which are slippery from the freezing of exhaust steam from the engine, is not negligent in law in using the steps in her exit from the building, although she knew of their slippery condition. Knowlton, J., devotes six pages to a learned review of the doctrine of Volenti non fit injuria, citing nearly fifty authorities. He finally observes : " Besides, there was evidence tend ing to show that she had no way of leaving the de fendant's mill except by going down the steps, and that was important to be considered in deciding whether she took the risk voluntarily." Well, we should say so! And we should say that this was absolutely decisive of the case without any discus sion of volenli non fit. She took the only way out provided by her employer, and owing to his negli gence was injured on that way. She was not bound to stay in the mill until warm weather, nor to jump out of window, nor to yell for the hook-and-ladder company. We should have decided that case in just four lines, as the learned judge substantially did when he had got over the case-learning that had nothing to do with the case. This volume contains thirty-one cases of negligence resulting in personal injuries! CONTRACT FOR BENEFIT OF STRANGERS. — This subject has been considerably mooted in the Ameri can courts, and the doctrine of the leading cases of King v. Whitely, i o Paige, 465, and Lawrence v. Fox, 20 N. Y. 268, although followed in that State, has met with some criticisms and limitations else where. In Jefferson v. Asch, Minnesota Supreme
