followed out the principles on which the prior decisions were founded to their logical conclusion, and enjoined the illegal, injurious action threatened, while not in the least interfering with the legal rights of the employés. The precedent is an admirable one, and if followed would go far to simplify the question of strikes. It is to be hoped Congress will adopt it, rather than the measures suggested by the report of the Judiciary Committee.

It is the more to be regretted that that body adopted such a course, as it is in line with the lax tendency noticeable in such matters of late years, and which led to the passing of the statutes of Pennsylvania and New Jersey already cited. Any encouragement of crime is sure to bring about a recrudescence of criminality; and this has been true in this case. The Pennsylvania statutes were followed by the Pittsburgh riots of 1877, the Reading strike and the Homestead strike; the legislation adopted by Congress after that last outbreak, forbidding the movement of armed bodies of men from one state to another, was followed by the New York strike and the coal strike in the bituminous coal regions; while the report of the Judiciary Committee on the Jenkins injunction was followed so closely by the Debs rebellion that its heels must have suffered considerably. The only effect of toleration of crime is to encourage it, and if that is not now clear with respect to strike legislation it never will be. The need is of repressive legislation, the more stringent the better, something that will teach the lawbreakers that they must respect the rights of others; and above all, measures that will render it impossible for any unprincipled, irresponsible demagogue to hold in his hands the welfare of a whole region.

The Annotations are prepared by the following Editors and Assistants : Department of PRACTICE, PLEADING AND EVIDENCE.

Hon. George M. Dallas, Editor. Assistants: Ardemus Stewart, Henry N. Smaltz, John A. McCarthy, William Sanderson Furst. Department of CONSTITUTIONAL LAW.

Prof. Christopher G. Tiedeman, Editor. Assistants: Wm. Draper
Lewis, Wm. Struthers Ellis.

Department of MUNICIPAL Corporations.

Hon. John F. Dillon, LL. D., Editor. Assistant: Mayne R. Longstreth.

Department of EQUITY.

Richard C. McMurtrie, LL. D., Editor. Assistants: Sydney G.
Fisher, John Douglass Brown, Jr., Robert P. Bradford.

Department of Torts.

Melville M. Bigelow, Esq., Editor. Assistants: Benjamin H. Lowry, Alex. Durbin Lauer, Patrick C. B. O'Donovan. DEPARTMENT OF CORPORATIONS.

Angelo T. Freedley, Esq., Editor. Assistants: Lewis Lawrence
Smith, Clinton Rogers Woodruff, Maurice G. Belknap, H.
Bovce Schermerhorn.

Department of CARRIERS AND TRANSPORTATION Companies. Charles F. Beach, Jr., Esq., Editor. Assistants: Lawrence Godkin, Owen Wister, Victor Leovy, Cyrus E. Woods.

Department of ADMIRALTY.

Morton P. Henry, Esq., Editor. Assistant: Horace L. Cheyney. Department of COMMERCIAL LAW.

Frank P. Prichard, Esq., Editor. Assistants: H. Gordon Mc-
Couch, Chas. C. Binney, Chas. C. Townsend, Francis H.
Bohlen, Oliver Boyce Judson.

Department of Insurance.

George Richards, Esq., Editor. Assistants: George Wharton.
Pepper, Luther E. Hewitt, Samuel Kahn Loucheim.

Department of CRIMINAL LAW AND CRIMINAL PRACTICE.
Prof. Geo. S. Graham, Editor. Assistants: E. Clinton Rhoads,
C. Percy Wilcox.

Department of PATENT LAW.

George Harding, Esq., Editor. Assistant: Hector T. Fenton.
Department of Property.

Hon. Clement B. Penrose, Editor. Assistants: Alfred Roland
Haig, Wm. A. Davis, Jos. T. Taylor.

Department of MEDICAL JURISPRUDENCE.

Hon. Marshall D. Ewell, LL. D., Editor. Assistants: Thomas
E. D. Bradley, Milton O. Naramore.

Department of WILLS, EXECUTORS AND ADMINISTRATORS.
Hon. Wm. N. Ashman, Editor. Assistants: Howard W. Page,
Charles Wilfred Conard, Joseph Howard Rhoads, William
Henry Loyd, Jr., Edward Brooks, Jr., Samuel D. Matlack.
Department of TRUSTS AND COMBINATIONS IN Restraint of
TRADE.

H. La Barre Jayne, Esq., Editor. Assistants: George S. Patterson,.
Charles F. Eggleston.

ROBINSON V. FLOYD ET AL. SUPREME Court of PENNSYLVANIA.

Partners of a banking firm who sell their interest and withdraw from the firm cannot by a mere publication of notice of such withdrawal in a newspaper, relieve themselves from liability for subsequent deposits by one who was a regular depositor for many years prior to such withdrawal; but a partner who gave actual personal notice to such depositor of his withdrawal, within three months thereafter, is not liable for such subsequent indebtedness.

NECESSITY FOR NOTICE UPON THE Dissolution of a PART

NERSHIP.

When a number of persons join themselves together for the purpose of carrying on any business or undertaking any kind of enterprise, each one thereby delegates to the other an authority, express or implied, to bind the members composing the partnership by an act or contract coming within the scope of the business for which the firm might be formed. Instances sometimes, if not frequently, occur where the authority of one member of a firm to bind the others will continue after the actual dissolution of the firm as between the parties themselves. But as to third persons and those dealing with the firm as creditors, the same continues to exist for all purposes until notice of the dissolution, actual or constructive, as the case may require, is given thereof. This wholesome rule of the law is founded on the soundest reason, and fortified by simple and natural justice. It is akin to the rule that holds the master liable for goods purchased by his servant 'Reported in 28 Atl. Rep. 258.

whom he sends to make purchases in the master's name, and where the servant, though his authority to make the purchases be withdrawn by the master, continues to buy of the dealer as before, the master not notifying the dealer that the servant's authority to buy goods on his credit is at an end. In short, the authority of the servant in the eye of the law is presumed to continue until notice to the contrary is given by the master. The rule is likewise grounded on the doctrine of equitable estoppel, as "where one party has by his representations or his conduct, induced the other party to a transaction to give him an advantage which it would be against equity and good conscience for him to assert, he would not in a court of justice be permitted to avail himself of that advantage." The servant is the agent of the master to buy goods on his credit. Good faith and fair dealing require the master to notify his dealer when that relation is ended. And so one partner is the agent of the others to bind them in all legitimate firm transactions; and when that authority is ended by the private agreement of the partners themselves, creditors of the firm and the public generally have a right to expect that the proper notice of the dissolution will be given and rely on this with assurance. Any other rule would open wide the flood-gates of fraud and facilitate all sorts of dishonesty and imposition.

There are two kinds of notice usually given when a firm retires from business and is succeeded by another, or is. dissolved by the withdrawal of one or more of its members. To the public in general, it is usually sufficient to relieve the retiring member from liability for debts contracted in the name of the firm by the remaining partner or partners if notice of the dissolution be published in some newspaper in the town,. vicinity or county where the business was carried on: Graves v. Gilbert, 7 Cow. 704; Lansing v. Gaine, 2 Johns. 304;. Ketchum v. Clark, 6 Johns. 144; Wilkinson v. Bank of Pa... 4 Whart. (Pa.) 482; Reilly v. Smith, 16 La. An. 31; Wheelock. v. McGovern, 28 Iowa, 533; Simonds v. Strong, 24 Vt. 642;: Mitchum v. Bank of Ky., 9 Dana, 166; Kennedy v. Bohannon, 11 B. Mon. (Ky.) 118; Graves v. Merry, 6 Cow. 701; Austin.

v. Holland, 57 N. Y. 571; Amidown v. Osgood, 24 Vt. 278; Haynes v. Carter, 12 Heisk. (Tenn.) 7; Bristol v. Sprague, 8 Wend. 423: Johnson v. Tolten, 3 Cal. 343; Meyer v. Khron, 114 Ill. 574; Moline Wagon Co. v. Rummel, 12 Fed. Rep. 658. On the other hand, all who have had dealings with the firm prior to the dissolution are entitled to actual notice: McLemore 7. Rankin Mfg. Co., 8 So. Rep. 845; Clement v. Clement, 69 Wis. 599; Morrill v. Bissell, 58 N. W. Rep. 324; Hall v. Heck, 92 Mich. 458; Moline Wagon Co. v. Rummel, 12 Fed. Rep. 658; Meyer v. Khron, 114 Ill. 574; Shamburg v. Abbott, 112 Pa. 6; Cogswell v. Davis, 65 Wis. 191; Gilchrist ~. Brand, 58 Wis. 184; Elkington v. Booth, 143 Mass. 479; Potts v. Taylor, 140 Pa. 601; Speer v. Bishop, 24 Ohio, 598; Wilkinson v. Bank of Pa., 4 Whart. (Pa.) 482; Reilly v. Smith, 16 La. An. 31; Simonds v. Strong, 24 Vt. 642; Mitchum v. Bank of Ky., 9 Dana (Ky.), 166; Kennedy v. Bohannon, 11 B. Mon. (Ky.) 118; Marsh, Denman & Co. v. Dosson, 19 La. An. 9; Pope & West v. Risley, 23 Mo. 185; Lyon v. Johnson, 28 Conn. 1; Merrett v. Williams, 17 Kan. 287; Stewart v. Sonnebarn, 49 Ala. 178; Zollar v. Jarvin, 47 N. H. 324; Graves. Merry, 6 Cowen (N. Y.), 701; Clapp v. Rogers, 12 N. Y. 283; Conro v. Port Henry Iron Co., 12 Barb. 27; Wardwell v. Haight, 2 Barb. 549; Vernon v. Manhattan Co., 22 Wend. 183; Prentiss v. Sinclair, 5 Vt. 149; Adam. Holtgrove, 85 Ill. 470; Dickinson v. Dickinson, 25 Gratt. 321; Austin v. Holland, 57 N. Y. 571; Nott v. Douming, 6 La. 680; Haynes v. Carter, 12 Heisk. (Tenn.) 7; Johnson v. Tolten, 3 Cal. 343; Brown v. Foster, 19 S. E. Rep. 299; Robinson v. Floyd, 28 Atl. Rep. 258; Rosenbaum v. Horton, 57 N. W. Rep. 609; Bristol v. Sprague, 8 Wend. 423.

The retiring partner is charged with notice of the fact that the remaining partners can bind him by contracts made in the name of the old firm, and it is his duty under the law to diligently search out all the old customers of the firm at his peril, and to see that they have actual notice of the dissolution: Amidown v. Osgood, 24 Vt. 278. And this is necessary whether the name of the retiring partner appear in the style of the firm or not: McLemore v. Rankin Mfg. Co., 68 Miss. 196.