directing the sheriff to retain him in jail, and that he be placed in a dungeon, without food or water, until he surrendered the clothes. Habeas corpus was then asked and granted. To this the sheriff answered that he detained and had the negro in custody, had had him in a dungeon as •ordered, but, that he was not held for any criminal or supposed criminal matter, but that he had not surrendered the clothing. His dis charge was again moved for and answer made that the difference between him and the sheriff, as to ownership of the clothing, must be determined in a civil court. This application, for discharge under habeas corpus, was denied, the negro ordered to stand up, and sentence passed as follows : " You shall be confined in jail until you divest yourself of those clothes, and I will see that this is done," with a side remark to the officer, "Put him in a dungeon and turn a stream of water on him." What may we not look for next? A statute of New York provided that if an officer in a corporation refused, on request of a stockholder, "to exhibit the books, or to submit them to an examination," he should forfeit a certain sum. The defendant contended that the stockholder could not take off a list of stockhold ers. " It was supposed," said the Court, " that the etymological meaning of the words " ex hibit" and "examine " limited their meaning to the construction contended for by the defendant. If the derivation be from examen, a swarm of bees, it may be supposed to imply the industry and perseverance of the bee, and would then authorize a search as thorough as the most earnest could desire; and not only a search, but that the best part of that which is searched, should be carried off to be converted to a good and useful purpose. Brouwer v. Cotheal, 10 Barb. 216. LITERARY NOTES. The definition, object, and sphere of taxation are treated by David A. Wells in Appletons' Popular Science Monthly for September. Many popular errors as to the nature of taxation, some centuries old, are pointed out in this paper. The same number contains an abstract of the recent studies of Enrico Ferri on " Homicide" among both savage and civil ized men, with some consideration of " crime among animals."
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In the September Review of Reviews the editor discusses different phases of the Presidential campaign — especially the revolt of the gold-standard Demo crats, the attitude of Eastern wage-earners toward Mr. Bryan, and the spread of free-silver doctrine among the farmers. Another important topic of dis cussion in the department of "The Progress of the World " is Lord Salisbury's Venezuelan proposition, in connection with the general scheme for a perma nent tribunal of arbitration. The editor also covers most of the striking developments of the month in British and European politics. The September Century abounds in articles of timely interest, and in an unusual variety of fiction. No serial story of the present time is attracting so much attention as Mrs. Humphrey Ward's "Sir Ceorge Tressady." Mr. Howells's lively story of Saratoga, "An Open-Eyed Conspiracy," is continued; and Mrs. Amelia E. Barr contributes the first part of a novelette, "Prisoners of Conscience," which deals with life in the Shetland Islands, and is strikingly illus trated by Louis Loeb. The short stories of the number are " Sonny's Diploma," by Mrs. Ruth McEnery Stuart; " Abner," by Lynn Roby Meekins; and "The Healing of Meechum," by Frank Crane. General Horace Porter's personal recollections of General Grant, which The Century will publish beginning in November, are to be called " Campaign ing with Grant." General Porter first met General Grant at Chattanooga; he soon became attached to his staff, and was with him constantly from that time until the close of General Grant's first term as Pres ident, during which he was Grant's private sec retary. The frontispiece of the September issue of the Na tional Magazine is the portrait of the great Chinese statesman, the Viceroy Li Hung Chang, whose present tour of the world is a matter of more than passing note. The leading article is a sketch of the Viceroy's life, outlining in a brief way the achieve ments of this Bismarck of the East. The illustrations accompanying the article are from photographs taken in China. The writer is Mr. Arthur W. Tarbell. "The Curse of the East," a descriptive paper written by C. H. Gibbons, dealing with the banishment of lepers on Darcey Island, is a decided magazine novelty. The photographs of the lepers and their cabins will be a revelation to the reading public. Mr. Edmund S. Hoch's second and last paper on "Yacht ing on the Great Lakes " appears in this number, with accounts and photographs of the most prominent yachts and yacht clubs on the inland Lakes.
