[91] See 16 Ohio St., 455, where a guardian was allowed; 41 N. J. Eq., 409, where the deaf were said to be liable to guardianship. [92] See 1 Jones Eq. (N. C.), 221. In 4 Johns. Ch., 441, a New York case in 1820, it was said by Chancellor Kent that the deaf and dumb were considered _prima facie_ as insane, incapable of making a will and fit subjects for guardianship, by the civil law. The presumption was due, he said, to the fact that "want of hearing and speech exceedingly cramps the powers of the mind," but it was to be overcome by proof. In this case the presumption was overruled. The implication, however, never applied to the deaf not born so. At present there is no presumption in connection with wills, deeds, witnessing, or guardianship. See 3 Conn., 299; 27 Gratt. (Va.), 190; 6 Ga., 324; 3 Ired. (N. C.), 535. In the Missouri case, quoted above, it was said: "Presumption of idiocy does not seem to obtain in modern practice, at least not in the United States." [93] The deaf as a class may be said to be strongly opposed to nearly all forms of legal treatment different from those of their fellow-citizens. In Texas, where they have been exempted from a personal or property tax, they have made formal protest against the exemption. _Annals_, l., 1905, p. 263; Report of Mississippi School, 1911, p. 72. They have, as another instance, voiced opposition to the release of criminals on the ground of their deafness. See Proceedings of Convention of National Association of the Deaf, ii., 1883, p. 16. CHAPTER IV ECONOMIC CONDITION OF THE DEAF EXTENT TO WHICH THE DEAF ARE A WAGE-EARNING AND SELF-SUPPORTING ELEMENT OF THE POPULATION In the want of the sense of hearing, and with it oftentimes the faculty of speech, the deaf are deprived of most important powers, and, it might appear, of an essential equipment for work among men. It is not to be denied that the deaf start out into life severely handicapped, nor can the difficulties which they must face in meeting the world pass unregarded. Yet notwithstanding the particular adversity under which the deaf have to labor, they remain in full possession of all their other physical forces, and it may be a question whether on the whole they are to be considered disqualified from engaging in the industrial pursuits of men. It may be that there are occupations in which their deafness will not prove of material consequence, and that in such fields they will be able to enter without serious impediment. In the present chapter we shall attempt to see how far these possibilities seem to be realized in the actual industrial life of the community. In other words, we shall consider what is the place of the deaf as economic factors in this life, and how far they are independent wage-earners, at the same time comparing their economic standing with that of the general population.