penitentiary labour not a punishment forced on the prisoner, but a matter of his choice and a reward for good behaviour, bringing with it better accommodations. His Code of Reform and Prison Discipline was adopted by Guatemala. Livingston was the leading member of a commission appointed to prepare a new civil code,[1] which for the most part the legislature adopted in 1825, and the most important chapters of which, including all those on contract, were prepared by Livingston alone. Livingston was again a representative in Congress during 1823-1829, a senator in 1829-1831, and for two years (1831-1833) secretary of state under President Jackson. In this last position he was one of the most trusted advisers of the president, for whom he prepared a number of state papers, the most important being the famous anti-nullification proclamation of the 10th of December 1832. From 1833 to 1835 Livingston was minister plenipotentiary to France, charged with procuring the fulfilment by the French government of the treaty negotiated by W. C. Rives in 1831, by which France had bound herself to pay an indemnity of twenty-five millions of francs for French spoliations of American shipping chiefly under the Berlin and Milan decrees, and the United States in turn agreed to pay to France 1,500,000 francs in satisfaction of French claims. Livingston's negotiations were conducted with excellent judgment, but the French Chamber of Deputies refused to make an appropriation to pay the first instalment due under the treaty in 1833, relations between the two governments became strained, and Livingston was finally instructed to close the legation and return to America. He died on the 23rd of May 1836 at Montgomery Place, Dutchess county, New York, an estate left him by his sister, to which he had removed in 1831. Livingston was twice married. His first wife, Mary McEvers, whom he married on the 10th of April 1788, died on the 13th of March 1801. In June 1805 he married Madame Louise Moreau de Lassy (d. 1860), a widow nineteen years of age, whose maiden name was Davezac de Castera, and who was a refugee in New Orleans from the revolution in Santo Domingo. She was a woman of extraordinary beauty and intellect, and is said to have greatly influenced her husband's public career. See C. H. Hunt, _Life of Edward Livingston_ (New York, 1864); Livingston's _Works_ (2 vols., New York, 1873); and Louise Livingston Hunt, _Memoir of Mrs Edward Livingston_ (New York, 1886). FOOTNOTE: [1] Preliminary work in the preparation of a new civil code had been done by James Brown and Moreau Lislet, who in 1808 reported a "Digest of the Civil Laws now in force in the Territory of Orleans with Alterations and Amendments adapted to the present Form of Government."