In 1889 a Negro woman in Illinois, having been refused tickets to a theatre, had a white man buy them for herself and her husband. On presenting the tickets they were refused admission to seats in the theatre which the tickets called for. At the resulting trial, the proprietor offered to prove that he had, “in order to avoid collision between the races, adopted a rule (and that such rule was necessary) to the effect that the colored people should have one row to themselves in each part of the house, or as many rows as the tickets which they bought would call for.” This evidence was rejected, the court[286] holding that the Civil Rights Bill of Illinois could not be satisfied by separate accommodations. Missouri has no Civil Rights Bill. A Negro, mistaken for a white man by the clerk in the box-office, bought tickets for seats in the orchestra of a Kansas City theatre. When he presented his tickets to the usher he was refused the seats called for, but was offered in exchange balcony seats reserved for Negroes. The court[287] before which the case was tried held that the rule of the theatre requiring separate accommodations for the races was not a violation of the Fourteenth Amendment. The most recent case[288] appears to be a 1905 case in New York in which a Negro was ejected from a theatre by an employee. The proprietor was permitted to show that the ejectment was done while he was away and contrary to his orders, and that he permitted Negroes to enjoy the privileges of the place. A verdict was thereupon found for him, but the case was remanded by the appellate court for a new trial, on the ground that the evidence was improperly admitted. SKATING RINKS California, Illinois, and Massachusetts have considered skating rinks of enough importance to include them in their Civil Rights Bills. In 1885 the keeper of a skating rink in Iowa refused to let a Negro use it, and the Negro brought suit. The court[289] held that the exclusion of a colored man from a skating rink not licensed is not illegal. The New York court[290] has held that a skating rink is a “place of public amusement” within the meaning of the statute, so that a keeper of one cannot refuse admission to a Negro. CEMETERIES The early Civil Rights Bills of New York, Florida, and Kansas prohibited race distinctions in public cemeteries. This stipulation, however, does not appear in the present statutes of any of the States, except Kansas. Race distinctions in cemeteries are common. The legislature of Mississippi[291] of 1900, for instance, gave the Ladies’ Auxiliary Cemetery Association, an organization of white women, permission to remove the monument and remains of the Negro State Secretary of State, James Lynch, from the white to the Negro cemetery in Jackson, Mississippi, provided it was done without expense to the State.