These two circumstances are, first, the decision of the Supreme Court of the United States upholding the Oregon ten-hour law for women, handed down since the decision in the Williams case was rendered; and second, the existence of many “facts of common knowledge” regarding the physical, moral and economic effects of night work, facts which were not brought to the attention of the New York Court of Appeals when it decided that Katie Mead was not likely to be injured by working at 10.20 P. M. in a given occupation. When the new case comes up for argument it is reasonable to hope that the New York court will follow the lead of the Supreme Court of the United States in taking “judicial cognizance” of those ascertained facts which go far beyond the single case at bar, and present to the court the world’s experience as to legislation of this character. CALIFORNIA WOMEN AND THE VICE SITUATION A red light injunction and abatement bill, not essentially different from the law now in effect in Iowa and Nebraska, passed both houses of the California Legislature with good majorities and was signed by Governor Hiram W. Johnson on April 7. The law declares houses of prostitution and assignation to be nuisances and holds responsible both the proprietor of the house and the owner of the building. It enables any citizen, whether personally damaged or not, to bring action; and it levies a fine against the property itself and forbids its use at any future time for such purpose.[2] The bill has had a somewhat dramatic history. In 1911 it was introduced at the request of the Woman’s Christian Temperance Union by Assemblyman Wyllie, but though favorably reported from the Public Morals Committee it was killed by re-reference to the Judiciary Committee too late to be returned to the floor. The tremendous general awakening since then on the subject of the social evil and the exposure in San Francisco of the enormous sums reaped by organized vice under the Schmitz-Ruef regime, led to the formation of a society of social hygiene. The efforts of the United States Department of Justice to suppress the traffic in girls led to the establishment of an anti-slavery society; and the State Board of Health, under the leadership of Dr. William F. Snow, made venereal, like other contagious diseases, reportable, though only by case numbers.