In Wilson v. Steel Edge etc. Co., 163 Mass. 315, the danger was a circular saw, and the employee was nearly twenty-one and had previously worked with such a machine, and on the present employment had re ceived some slight; practical instruction. In Stuart v. West End St. Ry. Co., 163 Mass. 391, the danger was a hay-cutting machine, but the employee was twenty years and six months old. The court evi dently deemed him adult, for they said: "In the early cases the doctrine was applied in favor of boys. In favor of adults it should be applied with great caution." The same may be said of Teazer v. Bur lington etc. R. Co. (Iowa), 61 N. W. Rep. 215, where the danger lay in a brakeman's mounting mov ing cars, and the employee was 19; and of Machin v. Alaska Ref. Co., 100 Mich. 276, where the machine was a planer, and the employee was 18; and of Crown v. Orr, 140 N. Y.450, the case of a planing machine, and of a boy of 19, who had worked in front of it for three weeks; and of Williamson v. Sheldon Marble Co., 66 Vt. 427, where the danger was in working on a narrow, icy, slippery ledge in the mine, and the em ployee was nearly 1 6 and earned $1 .15a day (there was no proof of failure to warn, and the employee had often done the work in question); and of Evansville etc. R. Co. v. Henderson, 33 N. E. 1021, 134 Ind. 636, where the employee was 19 and working on a con struction train; and of Herdman-Harrison & Co. v. Spehr, 145 III.329, where the employment was oiling moving machinery, and the employee was 17, but had done the same work for eighteen months. From this review it is apparent that(i) if the minor knows of the obvious danger from observation and experience, this is equivalent to warning and in struction; (2) that if the minor is of ordinary intelligence and nearly of adult years, he may be deemed to need no warning; (3) that otherwise he should be warned and instructed about the danger, although obvious. If the Arkansas case decides otherwise, it is the only case to our knowledge that so decides, and is incon sistent with that humanity and care which the law universally professes toward children . Certainly, up to the age of 16, children are heedless, unobservant, and reckless of danger, and it is the legal duty as well as an obligation of humanity on the part of one who em ploys them, to draw their attention at the outset to any danger in the situation, although it may be ob vious to an adult. The question whether warning and instruction are needed is generally regarded as one of fact.
Censorship of the Pkess. — The Kansas Su preme Court made a very wholesome decision, in Re Banks, 42 Pac. Rep. 694, that an act of the Legislature to prohibit the editing, publishing, circu
lating, disseminating and selling newspapers and other publications, " devoted largely to the publica tion of scandals, lechery, assignations, intrigues between men and women, and immoral conduct of persons," is constitutional. The Court also held that "largely" does not mean any definite amount, but it is sufficient if such items are a prominent feature and an especial characteristic. The Court said : — "The act under consideration was not passed to prevent the publication of libels, nor to suppress papers indulging in such publications, but to prevent the publication and sale of newspapers especially devoted to the publication of scandals and accounts of lecherous and immoral con duct. Without doubt, a newspaper the most prominent feature of which is items detailing the immoral conduct of individuals, spreading out to public view an unsavory mass of corruption and moral degradation, is calculated to taint the social atmosphere, and by describing in detail the means resorted to by immoral persons to gratify their pro pensities, tends especially to corrupt the morals of the young, and lead them into vicious paths and immoral acts. We entertain no doubt that the Legislature has power to to suppress this class of publications, without in any man ner violating the constitutional liberties of the press." The Penal Code of New York makes it a mis demeanor to publish " any book, pamphlet, magazine, newspaper, or other printed paper devoted to the publication, and principally made up of criminal news, police reports or accounts of criminal deeds, or pictures, or stories of deeds of bloodshed, lust or crime." This was aimed at the " Police Gazette," "Day's Doings," and other similar prints. " Town Topics" would hardly come in this category, but it would be obnoxious to the Kansas statute. Some of the vilest stuff ever uttered has appeared in this fashionable and filthy sheet. It is gratifying to see an effective blow anywhere dealt at the licentious power and habits of the press, especially at a time when the press demands larger license, and in one or two States has obtained it from legislators afraid of its hostility and ridicule.
Unchastity of Witness. — The Supreme Court of Missouri has fallen into some trouble about the doctrine of impeaching witnesses for unchastity. In State v. Grant, 79 Mo. 133; State v. Shields, 13 Mo. 236; 53 Am. Dec. 147, it was held that a female witness might be impeached by proof of her unchaste reputation. Subsequently feeling that what is sauce for the goose is sauce for the gander, the Court applied the same rule to male witnesses. State v. Rider, 95 Mo. 486; 104 ib. 441. Still later they seriously disagree whether they should not restrict the sauce to the goose. State v. Sibley, 33 S. W. Rep. 167. The doctrine of this kind of impeach-
