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rates for carriage wholly within the state by interstate carriers, has been much debated. "It seems to me quite obvious that if each state has this power, its exercise by all neces sarily and directly affects the rates for inter state carriage. "It is not just to these carriers, nor in my judgment is it expedient, to attempt thus to control them by so many different authorities. "Ultimately, I venture to say, it will be perceived that such efforts are an invasion by the states of the field of national sover eignty, and broadly speaking the entire authority over this subject will, by common consent, be remitted to the general govern ment." Considering the question whether this broadening jurisdiction of the general gov ernment threatens any grave consequences, a writer proposes as his subject:— "Will the Supreme Court become the Supreme Legislature of the United States?' By Clifford Thorne. 43 American Law Review 228 (Mar.-Apr.). "The development of our law as to the power of the legislature and the courts in fixing rates to be charged by the public ser vice corporations," says Mr. Thorne, "is prac tically the history of one case. . . . From time to time criticisms have been made upon the doctrine of Munn v. Illinois [94 U. S. 133; 24 L. ed. 77], but an impartial review of the cases must convince a fair-minded person that this noted decision has successfully withstood these attacks up to the present time. . . . Has our Supreme Court substantially aban doned the doctrine of Munn v. Illinois}" The attacks made in Chicago M. & St. Paul Ry. Co. v. Minnesota (134 U. S. 418, 33 L. ed. 970, 10 Sup. Ct. Rep. 462) in Budd v. New York (143 U. S. 517, 36 L. ed. 384, 12 Sup. Ct. Rep. 468), and in Brass v. No. Dakota (153 V. S. 391, 38 L. ed. 757, 14 Sup. Ct. Rep. 857), were unsuccessful, and "since 1901 there has been no direct attack upon the doctrine of Munn v. Illinois in the decisions of the Supreme Court. ... A careful read ing of Smyth v. Ames [169 U. S. 466, 42 L. ed. 819, 18 Sup. Ct. Rep. 418] will show that it makes no attempt to overthrow or alter the former decisions of the Supreme Court. . . . The doctrines of Smyth v. Ames in 1898 and Stone v. Farmers' Loan and Trust Co. [116 U. S. 307, 29 L. ed. 636, 6 Sup. Rep. 334] in 1886 are substantially the same. ... In no case up to the present time has the Supreme Court of the United States ever set aside any rates fixed by a legislative tribunal, which the court found would yield under ordinary cir cumstances some compensation above legiti mate expenses. . . . The doctrine of Munn v. Illinois has been embedded in our system of law by thirty-one years of experience. . . . "This condition of our law throws grave responsibility upon our legislatures. . . . Up to the present time the Supreme Court has steadfastly refused to encroach upon the functions of the legislature as outlined in Munn v. Illinois. . . . This example of our
Supreme Court, which alone has no superior to define the limits of its activity, this refusal by that august body to gradually extend its jurisdiction over functions exercised by another department of our government is a profound example not only of judicial wis dom, but of far-sighted statesmanship." Corruption. "Attempted Apologies for Political Corruption." By Robert C. Brooks. International Journal of Ethics, v. 19, p. 297 (Apr.). "These are, first, that political corruption makes business good; second, that it may be more than compensated for by the high effi ciency otherwise of these who engage in it; third, that it saves us from mob rule; and fourth, that corruption is part of an evolu tionary process the ends of which are pre sumed to be so beneficent as to more than outweigh existing evils." The same writer discusses "The Nature of Political Corruption," in Political Science Quarterly, v. 24, p. 1 (Mar.). "Reformers should learn," he says, "to bring down all direct and personal accusations to the level of existing law, until they have succeeded in bringing the level of the law up to their ideal standard." Oklahoma. "The Constitution of Okla homa." By Charles A. Beard. Political Science Quarterly, v. 24, p. 95 (Mar.). Canada and British Empire. "The Supreme Court and the Nation." By Walter H. Trueman. 45 Canada Law Journal 177 (Mar. 15). "While the Judicial Committee has attracted to itself a great deal of business, because of its high efficiency, it is doubtful if it were com posed to a considerable extent of members from the different parts of the Empire, the same need would be felt of resorting to it that now exists. The utmost that can be said in favor of a central court for the Empire is that it would have an immense sentimental aspect. That it is required in order that there may be a competent elucidation of the legal questions that arise within the Empire, I scarcely believe can be proven if colonial courts were made up of the best men avail able. . . . The litigation that arises within the Empire is not a matter falling within the purview of its Imperial concerns, but is a subject of local interest. A scheme of Empire which consistently preserves to each of its constituent parts complete autonomy as to all domestic affairs as an arrangement founded on convenience and necessary for the full development of its individual nationality, will, I should think, so regard it." "The House of Lords and Taxation." By Ernest E. Williams. Fortnightly Review, v. 85, p. 760 (Apr.). France. "The Political Capacity of the French." By James Thomson Shotwell. Po litical Science Quarterly, v. 24, p. 115 (Mar.).
