but it is also a tax on large business transactions which is ultimately paid by the consumer. Reform is needed to secure justice to the rich. The substantive law which determines the scope of rights and duties has been more completely overhauled, and many great improvements have been accomplished. Relations between the public and the great corporations which furnish transportation and other essential services are no longer left to the arbitrary decisions of corporate officers or the slow process of isolated litigation. Public service commissions do not yet operate perfectly, but any one who doubts their desirability should read a contemporary Commission Report and then turn to the history of the Erie Railroad under Jim Fiske and Jay Gould as related in “The Book of Daniel Drew.” The old fellow-servant rule which threw the burden of an industrial accident upon the victim has been changed by workmen’s compensation acts which place the risk upon the employer. He pays for the injured workman as for a broken machine and shifts the expense to his customers as part of the costs of the business. The burden is distributed through society and litigation is rapid and inexpensive. Unfortunately, no such satisfactory solution has been reached in the law of labour organizations, but its chaotic condition only corresponds to the general American uncertainty on the proper treatment of such organizations. It is possible that just as the King, in the Middle Ages, insisted on dragging the Barons into his courts to fight out their boundary disputes there, instead of with swords and battleaxes on the highway, so society which is the victim of every great industrial dispute will force employers and workmen alike to settle their differences before a tribunal while production goes on. The Australian Courts of Conciliation have lately been imitated in Kansas, an experiment which will be watched with close interest. Less importance must be attached, however, to the development of particular branches of the law than to the change in legal attitude. The difference between the old and the new is exemplified by two extracts from judicial decisions which were almost contemporaneous. Judge Werner, in holding the first New York Workmen’s Compensation Act unconstitutional, limited the scope of law as follows: