the future to disclose what cases, if any, of taking for uses which the state constitution, law and court approve will be held to be forbidden by the Fourteenth Amendment to the Constitution of the United States.” It thus appears that it would require an extreme case of manifest abuse of the power of eminent domain to lead the Supreme Court of the United States to condemn as private a use which a state legislature had recognized as public, and which had been sustained by the Supreme Court of the state. If the abuse of power were manifest, the United States courts would not hesitate to condemn the proceeding, even though expressly sanctioned by the constitution of a state; but there is every reason to believe that any method of taking and selling land justified by the reasonable purpose of controlling the environs of a public place would withstand the scrutiny of the United States Supreme Court if sanctioned by the legislative and judicial departments of the state government. In concluding this topic, some experiments made in other states towards taking more property than was demanded by the physical requirements of an improvement, either to control the environs or for mere pecuniary considerations, may be passed briefly in review. The experience of foreign countries need not be recounted here, since some governments, unlimited by constitutional restrictions, have conducted real estate transactions of a wide range, far beyond anything that could reasonably be contemplated in America. The State of New York had upon its statute books early in the last century an act already adverted to, purporting to authorize municipalities to take all of a connected tract of land when only part was needed and to sell the surplus. This statute was adjudged by the courts to be unconstitutional, in so far as it sought to authorize the taking, against the owners’ consent, of land not actually needed. A resolution, however, has, after many years, been introduced (January 27, 1909), in the senate of the State of New York for the submission of a constitutional amendment in the following language: “When private property shall be taken for public use by a municipal corporation, additional adjoining or neighboring property may be taken, under conditions to be prescribed by the legislature by general law. Property thus taken shall be deemed to be taken for public use.”