EDITORIAL DEPARTMENT

something towards settling the more debat able areas in his classification. Thus here, as elsewhere, the volume has the excellent trait of awakening interest and encouraging further investigation. CONSTITUTIONAL LAW (Restricting Hours of Labor). " Due Process of Law and the Eight-Hour Day," by Learned Hand. Har vard Law Review (V. xxi, p. 495). Arguing that the possible wisdom *of an eight-hour law, and therefore its validity, being already fairly within the field of rational discussion, should be passed upon by the legislative body and not by the court. CONSTITUTIONAL LAW (Michigan). "The Michigan Constitutional Convention," by John A. Fairlie. Michigan Law Review (V. vi, p. 535). An account of the conven tion and exposition of the important changes in the revised constitution which is to be sub mitted to popular vote in November. CONTEMPT OF COURT (Libel by a Stranger). " The King v. Almon I," by John Charles Fox. The Law Quarterly Review (V. xxiv, p. 184). The judgment in Rex v. Almon (1765, Wilmot's Notes, p. 243), an attachment for libeling the Chief Justice, Lord Mansfield, was prepared but never delivered, as the prosecution was dropped. The case has, .however, often been cited. Pointing out certain distinctions between contempt of court by disobedience to process by a party and contumelious behavior to the court by a party or a stranger, the author says the first adoption of the summary juris diction upon contumelious behavior has not been clearly traced, but instances can be cited to show the early practice. It is the object of the present paper to show that the jurisdiction in the case of a libel on the court by a stranger (the offense in Almon case) was the latest to be established, and that no recorded instance is to be found earlier than the eighteenth century. It is to be con tinued. CONSULAR COURTS. "American Con sular Jurisdiction in the Orient," by Frank E. Hinckley, Doctor of Philosophy, Columbia University School of Political Science; Clerk of the United States Court for China. Wash ington, 1908. 8vo, pages 283. This is hardly a law book but, as the titles of the author wouldjindicate, is an historical

and descriptive statement of the jurisdiction exercised by the United States Consular Courts in Turkey, Egypt, and China. It gives an excellent summary of the history of Capit ulations and Treaties conferring Exterri toriality in the Orient, and in particular a statement of the American Treaties. Then follows an examination of the acts of Congress for the establishment of Consular Courts and a description of the nature and jurisdiction of such, courts and a brief and elementary dis cussion of the rights and liabilities dealt with in such courts. An appendix contains pertinent treaties, statutes, and executive orders, rules of court, and other interesting matter. While the book can hardly be described as possessing independent authority it is a handy compila tion of information which would be useful to any one having to do with the Consular Courts of the United States. CONSULAR COURTS. " Consular Juris diction and Residence in Oriental Countries," by Sir Francis Piggott, Chief Justice of Hong Kong. New edition, revised and enlarged. Hong Kong and London, 1907. 8vo, pages 326. This is a new edition of Judge Piggott's ex cellent little book on Exterritoriality. While he deals only with the English Statutes and Cases the scholarly and lawyer-like quality of his discussion makes it a book which will be of the greatest assistance to American lawyers having occasion to deal with the subject. While a large part of the work consists of the statement and interpretation of the British Statutes governing the powers and the opera tion of Consular Courts, Judge Piggott goes at length and thoroughly into such questions as the nature of the power exercised under the treaty by a Consular Court, the power of Parliament to direct the action of such courts, and the application of the Oriental Law of Marriage and Divorce to the case of Mixed Marriages. Judge Piggott's conclusions ap pear to be entirely sound, and his criticisms of some of the English decisions are accurate and just. He takes the ground which is now firmly fixed in "England that in exercising its treaty power the Consular Court is acting merely as an agency in the native government. He further concludes that any act of Parliament