[81] According to the English Corrupt and Illegal Practice Prevention Act of 1883, bribery as the unauthorised act of an agent renders the election invalid and disqualifies the candidate from representing the constituency in which the offence was committed for seven years. While the penalty may seem drastic it has the good effect of compelling candidates to scrutinise expenditures in their behalf with a degree of anxious care seldom duplicated on this side of the Atlantic. [82] Missouri, L. 1907, p. 261. This law was declared unconstitutional in 1908, however, on the ground that it impaired liberty of press and speech. _Ex parte Harrison_, 110 S. W. 709. [83] A similar provision was included in the Massachusetts law of 1892. [84] A Michigan law which went into effect in 1892 (Repealed, ch. 61, 1901) provided that all expenditures on behalf of candidates, with few exceptions, should be made through the party committees. [85] Following the four states which took action in 1897, Kentucky forbade corporate contributions in 1900. In 1905, Minnesota (ch. 291) made it a felony for an officer of a business corporation to vote money to a campaign fund. Wisconsin in the same year (ch. 492) made it a felony for a corporation to contribute to political parties for the purpose of influencing legislation or promoting or defeating the candidacy of persons for public office. New York in 1906, (ch. 239) prohibited political contributions by corporations and made violation of the act a misdemeanor. Alabama, Iowa, North Dakota, South Dakota, and Texas were the five states which forbade corporate contributions in 1907, and the following eleven were reported as specifically prohibiting contributions from life insurance companies in that year: Delaware, Indiana, Michigan, Minnesota, Montana, New Hampshire, New Jersey, North Carolina, North Dakota, Tennessee, and West Virginia. In 1908, Ohio, Georgia, Massachusetts, and Mississippi also forbade corporate contributions. Altogether to the end of 1908, seventeen states had forbidden corporate contributions in general, and eleven had specifically forbidden contributions from life insurance companies. [86] Massachusetts, L. 1908, ch. 85. [87] Ohio, L. 1896, p. 123; repealed, L. 1902, p. 77. [88] Nebraska in L. 1899, ch. 29, fixed the same maxima and minima as the Garfield Act. The sliding scale principle was employed in the English Act of 1883. [89] California, L., 1893, ch. 2; Missouri, L. 1893, p. 157; Montana, Penal Code, 1895, sec. 80 ff.; Minnesota, L. 1895, ch. 277; and New York, L. 1907, ch. 584. [90] New York, L. 1895, 155; Connecticut, L. 1895, 338. [91] California, L. 1907, ch. 350. [92] New York, L. 1906, ch. 503. [93] _Cf._ p. 177, _supra_. [94] See p. 250, _supra_. [95] _Cf._ p. 246, _supra_. [96] Wisconsin, L. 1897, 358. [97] _Cf._ President Arthur T. Hadley’s discussion of “The Constitutional Position of Property in America” in the _Independent_ of April 16, 1908.