agreement that they should adopt, rear and educate her, and at their death leave her all the property they might own,—in pursuance of which she lived with them till they died, taking their name, and being taught to consider them her father and mother, and her real parents her uncle and aunt,—but the adoptive parents did not devise to her a certain piece of real estate, the facts amounted to such a part performance of the agreement as would entitle her to a decree giving her possession of the land by way of specific performance. The Court of Civil Appeals of Texas has very properly ruled that a change in the Christian name of a defendant is not such an amendmeṇt as will give him the beneAmendment fit of the statute of limitations: Middlebrook v. David Bradley Mfg. Co., 27 S. W. Rep. 169; and the Supreme Court of Wisconsin holds, in accordance with the weight of authority and principle, that when the record in a criminal case, through the negligence of the clerk, fails to show that the defendant was present at all times during the trial, it may be amended to show such facts, on the testimony of the clerk and the sheriff, after the defendant has sued out a writ of error, and at a subsequent term: Hoffman v. State, 59 N.W. Rep. 588. The Supreme Court of Minnesota holds that when all the orders of an award are to be performed by one party, some of which are good and some bad, the latter fact will not discharge the party as to those which are Arbitration, Award good: Bouck v. Bouck, 59 N. W. Rep. 547. When an insolvent debtor executes a chattel mortgage to several creditors, with power of sale, conditioned that any surplus over their claims shall be returned to the for benefit of grantor, such an instrument is not to be construed Assignment creditors as a general assignment for the benefit of creditors, according to the Court of Appeals of Colorado: McCordBragdon Co. v. Garrison, 37 Pac. Rep. 31; nor is a trust deed, under such circumstances, as decided by the Court of Civil Appeals of Texas: Collins v. Sanger, 27 S. W. Rep. 500; nor, in the opinion of the Supreme Court of Nebraska, will such be the effect of several chattel mortgages made simulta neously, covering all the property of the debtor, and leaving other creditors unsecured, though there be an agreement among the creditor mortgagees to share pro rata in the proceeds: Smith v. Phelan, 59 N. W. Rep. 562. A creditor, however, who after assignment levies upon and sells a part of the assigned property, and retains the proceeds, is held by the Court of Appeals of Colorado not to be entitled to participate in the assignment: Beifeld v. Martin, 37 Pac. Rep. 32. According to the Supreme Court of Arkansaș, the priority of an attachment is lost when the plaintiff, at the time of placing the writ in the officer's hands, tells him Attachment, not to serve it unless some other person gets out an attachment; and another writ, placed in the hands of the officer before that order is countermanded, will take precedence: Florsheim Bros. Dry Goods Co. v. Geo. Taylor Com. Co., 27 S. W. Rep. 79. Attorneys The cause of woman's rights has just met with notable encouragement from the Supreme Court of New Hampshire. In In re Ricker, 29 Atl. Rep. 559, that court, after a thorough investigation into the nature of the attorney's calling, his powers, duties, and responsibilities, has decided, that the vocation of a member of the bar, as an attorney and an officer of the court, is not a public office, within the common-law rule which excludes women from government by withholding electoral and official power, and that rule does not therefore prevent a woman from being licensed to practice as an attorney. The reasoning which supports this opinion is very able and cogent, and would probably prove convincing to any unprejudiced student of the question, but most men are unfortunately very strongly prejudiced on this score, and the weight of authority is rather against this view: Re Bradwell, 55 Ill. 535; Bradwell v. State, 16 Wall. 130; Re Lockwood, 9 Ct. Cl. 346; Re Goodell, 39 Wis. 232; Robinson's Case, 131 Mass. 376; Re Leonard, 12 Ore. 93; S. C., 6 Pac. Rcp. 426. that in all these cases the decision is But it is worth noting based more on esthetic than legal grounds-such as the impropriety of permitting women to handle the filth which is so apt to defile a lawyer's hands in certain classes of cases, and the like; that in most of the states where the right has been refused, that refusal has been followed by an express grant from the legislature; and that the tendency of the more recent cases has been almost uniformly in favor of the admission of women: Re Mary Hall, 50 Conn. 131; S. C., 21 Am. L. Reg. (N. S.) 728; Re Kilgore, 14 W. N. C. 466; S. C., 17 W. N. C. 475, 562; Re Thomas, 16 Colo. 441; S. C., 27 Pac. Rep. 707; Re Leach (Ind.), 34 N. E. Rep. 641. An attorney's lien for services cannot be successfully asserted against money appropriated to the client by act of the legislature, while such money is in the custody or under the control of the state treasurer, by the decision of the Supreme Court of Nebraska: State ex rel. Sayre v. Moore, 59 N. W. Rep. 755; and according to the Supreme Court of Oregon, a district attorney is entitled to but one fee, where several persons are jointly indicted for the same offence, and jointly tried: Union Co. v. Hyde, 37 Pac. Rep. 76: Beneficial The Supreme Court of Nebraska has laid down a very reasonable rule with regard to membership in a railroad relief association, in Burlington Vol. Relief Dept. v. Associations White, 59 N. W. Rep. 747, by holding that when the department, with knowledge of the fact that no formal application for membership had ever been made, caused assessments to be deducted from a supposed member's pay on the basis of such membership, it was thereby estopped from disputing his membership. Of even more importance to the beneficial societies of which this country is full, was the decision of the Supreme Court of Errors of Connecticut, in Fawcett v. Supreme Sitting of Order of Iron Hall, 29 Atl. Rep. 614, to the effect (1) that when the certificate issued promises to pay $1000 in seven years, on payment of $2.50 on each assessment, but is silent as to the number of assessments to be made, the society cannot be said as a matter of law to be guilty of fraud; and (2) that when a beneficial organization doing business in several states becomes insolvent, and a receiver of all its estate is appointed by a court of the state in which it was incorporated, a receiver appointed in one of the other states is not bound to pay over to him the reserve fund held by its branches in that state, though claimed by the general receiver for general distribution among certificate holders, but those funds should be retained for distribution in their own state, on the election of the certificate holders to treat the contract as rescinded and demand a return of the payments thereon. The Court of Appeals of Maryland refused to allow a similar claim made by a general receiver appointed for the state against local receivers, unless the former could show that their authority extended to the local branches, and that the property in the hands of the latter belonged to the Supreme Sitting and not to the local branches: Weiner v. Sturgiss, 29 Atl. Rep. 613. These decisions, however, are rather questionable innovations on the general rule in such cases, which is, as truly said by Hamersley, J., in his dissenting opinion in the Connecticut case, that when a corporation is chartered by a single state, and does a lawful insurance business in other states, through agencies, and becomes insolvent, its assets should be gathered at the domicile and there distributed according to the principles of equity. Boundaries The Supreme Court of Nebraska, following the decision. of the Supreme Court of the United States in Nebraska v. Iowa, 12 Sup. Ct. Rep. 396, has lately reasserted the general rule, that when the middle of a stream is the boundary between two estates, and the water undermines the bank on either side, so that it caves in, the owner of the land stands the loss, and the middle of the stream is still the boundary, but that if the stream makes itself a wholly new bed by cutting across a bend or neck, the middle of the old bed remains the boundary, though dry: Bouvier v. Stricklett, 59 N. W. Rep. 550. And the Supreme Court of Indiana has ruled, that land described as bounded by the line of a railroad extended to the line of rails, if the grantor could convey so far, and not simply to the right of way: Reid v. Klein, 37 N. E. Rep. 967. Carriers The constantly mooted question as to the liability of common carriers with connecting lines has been considerably elucidated by the published decisions of the past month. The Supreme Court of Minnesota has held that such carriers do not become joint carriers by establishing joint or through tariffs or rates, but the one receiving the goods becomes the agent of the others to contract for carriage over their respective lines: Wehmann v. Minn., St. P. & S. M. Ry. Co., 59 N. W. Rep. 546. The Court of Civil Appeals of Texas has decided that when connecting carriers are partners in the transportation of freight, the initial carrier cannot by contract limit its liability for injuries to through freight to such injuries only as occur on its lines: Gulf, C. & S. F. Ry. Co. v. Wilbanks, 27 S. W. Rep. 302; and the Supreme Court of Michigan has taken the ground that when a shipper knows that his goods must be delivered to a connecting line, and agrees that after the goods leave the receiving road it shall be treated as a forwarder only, the receiving road will not be liable for a conversion by the connecting line: McEacheran v. Mich. Cent. Ry. Co., 59 N. W. Rep. 612. Apropos of the general subject of liability, the Supreme Court of Minnesota also held, in the case from that state last cited, that a stipulation that a common carrier should be relieved from liability needs a consideration to make it binding; that the mere receipt of goods and undertaking to carry them is not such a consideration; and that no abatement or concession in rates, when forbidden by law, can form a sufficient consideration: Wehmann v. R. R., supra. But the Supreme Court of Missouri has ruled that a statute, which provides that a common carrier shall be liable for any loss caused by its own negligence, or that of any connecting carrier, does not prohibit a carrier from contracting with the shipper against liability beyond its own line: McCann v. Eddy, 27 S. W. Rep. 541. In the opinion of the Supreme Court of Indiana, the board |