an increase in the second-class postal rates from one to two cents a pound except on newspapers. The estimated surplus for the fiscal year of 1914 was $3,569,545.-In his annual report the secretary of war recommended the addition of 1000 officers and 25,000 men to the regular army and a more adequate provision of artillery and artillery ammunition.---The secretary of the treasury, in his annual report, commenting upon the evasions of the income-tax law, proposed an amendment requiring all those with a gross income of $3000 and over to make returns.—The annual report of the secretary of the navy recommended the creation of a naval reserve consisting of enlisted men who had been honorably discharged. The chief of the bureau of navigation indicated serious shortcomings in the personnel of the navy above all, a shortage of 18,000 in the enlisted force, an abnormal distribution of officers of the line and a deficient system of promotions.--In November the report of Major-General Wotherspoon, the retiring chief of staff, called attention to the inadequacy of the military establishment. He accepted later an appointment under Governor Whitman of New York. In March it was reported that during the first six months of operation the Panama Canal had handled 496 vessels aggregating 2,367,244 tons and paying tolls of $2,138,442. The cost of maintenance slightly exceeded the income.-An outbreak of Piute Indians occurred near Bluff, Utah, late in February, and occasioned some loss of life.-On February 22 the President nominated the five members of the Federal Trade Commission: Joseph E. Davis, W. J. Harris, W. H. Parry, R. N. Hurley, and George Rublee. These nominations were confirmed, though there was some delay in the case of Mr. Rublee. Other appointments included Brigadier General H. L. Scott as chief of staff; Henry C. Hall as member of the Interstate Commerce Commission; Samuel L. Rogers as director of the census; and Robert W. Wooley as director of the mint.

CONGRESS.—The short session of the sixty-third Congress opened on December 7, and on the following day President Wilson read his message before a joint assembly of the two houses. He recommended the passage of the Jones bill, providing for a larger measure of self-government in the Philippines, and of two conservation bills which regulated the use of mineral lands and water power. After considering the effects of the European war upon sea-borne trade and the lack of the necessary shipping facilities for the American export trade, he urged strongly the passage of the ship-purchase bill which had been laid before Congress in the previous session. As to the regulation of business the government program was described as "virtually complete"; business could now go forward with perfect confidence. That part of the message which aroused most attention dealt with national defence. Decrying the agitation for increased armaments, the President said that the reliance of the nation must depend, as in the past, "upon a citizenry trained and accustomed to arms" and particularly upon a powerful navy which "we have always regarded as our proper and natural means of defence."-The President's insistence on the

passage of the ship-purchase bill (see last RECORD, p. 739) led to a bitter conflict in the Senate, a break in the Democratic ranks and finally a damaging defeat. The bill, as amended in the Democratic caucus on January 23, was met with a determined Republican filibuster. The Senate sat continuously for 37 hours; long speeches were made, Senator Smoot holding the floor for nearly twelve hours. If all the Democrats had stood by the caucus decision, the protracted resistance might have been overcome; but at the critical juncture seven insurgents, who demanded amendments which would obviate the possibility of complications with any of the belligerent nations, broke away. The Democratic leaders themselves then resorted to dilatory tactics pending the return of two absent members and efforts which were being made to secure Republican votes and to win back the insurgents. For a time Senators Kenyon, Norris and LaFollette gave their support to the bill. On February 8, for the first time in almost twenty years, every senator was in attendance; the opposing forces were equally balanced. The Republicans, in order to prevent a decision by the casting vote of the Vice-President, resumed their filibuster; Senators Kenyon and Norris, not wishing to have important appropriations indefinitely delayed, deserted their allies; and when adjournment was taken on February 10, after a continuous session of 52 hours and 10 minutes, it was evident that the filibuster had succeeded. The administration leaders, changing their tactics, then turned to the House and under a special rule forced through a compromise bill on February 17. The vote stood 215 to 122, all Republicans and 19 Democrats opposing. The new measure, which took the form of an amendment to the naval auxiliary bill previously passed through the Senate (see last RECORD, p. 739), provided that the government should operate merchant ships until two years after the close of the European war, that the ships should then be transferred to the navy, and that the secretary of the navy should lease to private firms such ships as were not necessary for naval purposes. It was found impossible, however, to secure sufficient support for this bill in the Senate.-The filibuster served to draw attention once more to the absence of restrictions upon debate in the Senate and to the abuses to which that freedom was liable. On March 2 most of the Democratic senators united in a petition to Senator Kern asking for the appointment of a committee to consider modifications in the rules. Senator Kern appointed a committee of five, headed by Senator Owen and composed of influential men who are known to favor the use of the closure. It will report to the Democratic caucus.—The failure of his ship-purchase bill was not the only rebuff which President Wilson met in the Senate. In December a conflict arose over federal patronage. In conformity with the rule of "senatorial courtesy" the Senate unanimously rejected a nomination to the office of district attorney in New York and a nomination to the office of postmaster in Missouri. This action was taken on the ground that the President had failed to secure the concurrence of Senator O'Gorman and Senator Reed.-There was nothing in the President's message referring

to the immigration bill which had passed the House in February, 1914 (see the RECORD of June, 1914, p. 357); but on December 31 the Senate passed the bill, with certain amendments, by a vote of 50 to 7. The House, after rejecting the Senate amendments, adopted the conference report 227 to 94. On January 28 the President vetoed the bill, disapproving the literacy test and the restrictions which would tend to deny asylum to political refugees. It was found impossible to secure the necessary two-thirds to override the President, the vote in the House being 261 to 136.-A bill designed to improve the condition of seamen and to provide for the safety of passengers was passed in February. It is applicable to all vessels leaving American ports. After much discussion as to the adequacy of the naval establishment, the naval appropriation bill was adopted by both houses on March 2. It provides for 2 battleships, 6 destroyers, 18 submarines and for the development of the aeroplane service.-On March 3 Congress passed a resolution designed to strengthen the powers of the president in the enforcement of neutrality laws and especially to prevent American territory from being used as a base for supplying belligerent ships of war.-On December 22 a resolution proposing the establishment of national prohibition by constitutional amendment passed the House of Representatives 197 to 189, failing to secure the necessary two-thirds.-On January 12 a proposed constitutional amendment for the establishment of woman suffrage was defeated in the house by a vote of 174 to 204. The vote was probably affected by the statement of President Wilson that woman suffrage should be treated as a state, not as a national, question.

FEDERAL JUDICIARY.—Among the more important decisions of the Supreme Court were the following. Where a person charged with crime has, after confession, been sentenced to a fine and costs and then been released on payment of the fine by a surety with whom he has made an agreement to work continuously for a specified period, as provided by the laws of Alabama, the relation between that person and the surety is one of peonage and falls within the prohibition of the thirteenth amendment (United States v. Reynolds, 235 U. S. 133). An agreement made by the states of North Carolina and Tennessee giving commissioners the power to exercise final judgment in fixing the boundaries between them does not violate the clause of the federal constitution forbidding agreements between the states (North Carolina v. Tennessee, 235 U. S. 1). An Omaha ordinance requiring a railroad to construct a viaduct over its line at a street crossing is not unconstitutional as taking property without due process of law (Missouri Pacific Railroad Company v. Omaha, 235 U. S. 121). Where the evidence is undisputed and shows a discrimination between localities, a finding by the Interstate Commerce Commission is not subject to review by the Commerce Court (United States v. Louisville and Nashville Railroad Company, 235 U. S. 314). Transportation between ports of a state is not interstate commerce to the extent of being excluded from the taxing power of the state because a part of the journey is over the territory

of another state (Cornell Steamboat Company v. Sohmer, 235 U. S. 551). In a workmen's compensation law establishing a state plan which all employers having five or more employees may enter on equal terms, a provision abolishing the defence of contributory negligence as to such employers as do not come within the plan does not deny the equal protection of the laws (Jeffrey Manufacturing Company v. Blagg, 235 U. S. 571). An order of the Georgia railroad commission which requires a railroad to desist from demanding freight charges in advance on merchandise received from one carrier while it accepts merchandise of the same character at the same point from another carrier without such prepayment is not so arbitrary as to constitute a violation of the due-process clause of the fourteenth amendment (Wadley Southern Railway Company v. Georgia, 235 U. S. 651). A woman who is transported in violation of the white slave traffic act may be guilty of conspiracy with the person transporting her to commit a crime against the United States (United States v. Holte, 236 U. S. 140). In the absence of any action by Congress a state may, through its railroad commission, prevent exorbitant charges for transportation having origin and termination within the state and none of it being within any other state, although a part of it may be over the high seas (Wilmington Transportation Company v. California Railroad Commission, 236 U. S. 151). A Washington statute intended to prevent the wilful printing and circulation of written matter having a tendency to encourage disrespect for the law is not unconstitutional under the due-process clause of the fourteenth amendment (Fox v. Washington, 236 U. S. 273). Since the Indiana statute requiring railroad companies to place certain appliances on every car has been superseded by the federal safety-appliance act, penalties imposed by the former cannot be recovered as to cars operated on interstate railroads even though being employed only in intrastate commerce (Southern Railway Company v. Railroad Commission of Indiana, 236 U. S. 439).

STATE AFFAIRS.-The seventh conference of governors began its sessions at Madison, Wisconsin, on November 10, 36 members being in attendance. Among the subjects discussed were uniform registration of land titles under the Torrens system, incorporation of land-mortgage banks, uniform child-labor laws and state control of natural resources.-Prohibition will be effective at the opening of 1916 in eighteen states, action having been taken in nine of them within the last seven months. The last states to act, proceeding by way of statute instead of constitutional amendment, were Arkansas, Idaho and Iowa in February, and Utah in March. Constitutional amendments have been passed through the legislature in Iowa, Montana, and South Dakota; in Vermont the question was referred to the electorate; in Iowa a second passage through the legislature is required. In Minnesota a local option measure was adopted; in New York and Pennsylvania similar measures were defeated. The Albany legislature passed over the governor's veto a bill prohibiting the publication or circulation of newspapers which contain liquor advertisements and prohibiting

In Illinois the cleavage

circular and billboard advertisement of liquor. within the Republican party on the subject of prohibition made it impossible to elect a speaker of the lower house for five weeks. On the sixty-eighth ballot a combination of Republicans and Democrats overcame the prohibition advocates.—Resolutions providing for the submission to the people of constitutional amendments providing for woman suffrage were adopted by the legislatures of Arkansas, Iowa, Massachusetts, New Jersey, New York, Tennessee and West Virginia. They were rejected in North Carolina and South Dakota. In Indiana, following the example of Illinois, a statute was passed permitting women to vote for offices established by statute.—The United States district court, on January 7, declared invalid the Arizona statute which required that not more than twenty per cent of the employees of any firm or individual should be aliens.—The Illinois workmen's compensation law was held unconstitutional on December 30 because the bill had not been printed in the journal before passage.—In Indiana a preferential primary law was adopted in March applying to federal as well as state offices. ---The Kentucky workmen's compensation bill was declared unconstitutional by the state court of appeals on December 11. In February the trial of 1100 voters charged with bribery in the November elections began at Pikewell on February 1. A week later 17 convictions were secured.-On November 23 the state court declared the minimum wage law of 1913 unconstitutional on the ground that it delegated legislative power to an appointive commission and placed in that commission a discretion as to whether there should be a minimum wage. The law was also held to abridge the right of the individual to contract.-In February Nevada adopted a law reducing the residence required in divorce proceedings to six months.-The legislature of New York adopted a widowed mothers' pension bill which aims at preventing the separation of children from their mothers and their being sent to state institutions. The law is not mandatory, but simply permits the establishment of a board of child welfare in each county.-The New York constitutional convention, the first since 1894, held its first session on April 6. Elihu Root, former secretary of state and United States senator, was elected president. On January 12 the court of appeals unanimously affirmed the conviction of William Willett and Joseph Cassidy, former Democratic boss of Queens County, on bribery charges growing out of the effort to secure a judicial nomination for Willett in 1911 (see last Record, p. 741). The court reversed the conviction of Louis T. Walter who was jointly convicted with them.-On January 14 Governor Blease of South Carolina disbanded the state militia because of certain disagreements between himself and both state and national military officers. Three days later, and before the expiration of his term, he resigned. To that date he had pardoned 2704 persons, including some thirty convicted of murder.— In Vermont a controversy over the right of the governor in respect to judicial appointments was resolved in January when the legislature adopted a resolution setting a day for the election of the judges, whereupon the