The county is indeed a wonderfully bountiful base of supplies for the spoilsmen. The circumstance goes far to explain the slow growth of the merit system in this branch of government. Civil service laws are in force to-day in eighteen counties in New York, four in New Jersey, one in Colorado, one in Illinois, two in California and the more important counties in Ohio. That is the extent of the merit system in counties. Even in states like Massachusetts, Illinois and Wisconsin, where state-wide civil service laws affecting cities are in operation, appointments in the county offices are filled on the principle of “to the victor belong the spoils.” In New York State the courts have enunciated a principle with reference to the relation between the sheriff and his deputies which has the effect of fortifying the system against attack and its most prolific outlet. For, said the court in Flaherty _vs._ Milliken,[3] “the relation between a sheriff and his appointees is not merely that the sheriff is responsible for the default of his appointee, but that the appointee for said default is _liable to the sheriff and to no one else_.” “The practical operation of this rule of personal agency,” says the New York Civil Service Commission, “is in large measure to open the door for political purposes of persons in whom no real trust is reposed. These offices are in practice found to be a haven for political spoilsmen....” But “spoils” often connotes something besides jobs that pay salaries or fees. In Westchester County, N. Y., where county affairs are known to the public rather more intimately than elsewhere (owing to the activities of the local Research Bureau), it has been found that perhaps the richest patronage of all is in the county advertising. The state of New York requires, for instance, the publication in every county of the complete session laws of the legislature, in two papers. It means the setting up in newspaper type of two or more large legal volumes of intricate matter that no one could possibly use in that form. Then there are multitudinous formal legal notices that issue from the various offices at the court house, that rarely, in the nature of the case, interest more than the two or three parties who may never see them at all. Every paper that prints this material gets paid, often at a much higher rate than it would be compensated for ordinary commercial work. In one case an honest printer in Westchester County was so indiscreet and independent as to submit to the Board of Supervisors a bill at something approximating a fair rate,--$600. His rivals remonstrated and undertook to get him to raise his figure--they were charging $1060 for the same matter. But the independent said: “No, $600 is the legal price and moreover it is good pay.” The board audited his claim and of course cut down the rival papers accordingly,--but never thereafter did the county printing go to the man who wanted to be fair to the public.