Next following Miss Goodell’s case, came that of Lelia J. Robinson of Boston, in 1881, the Supreme Judicial Court holding that under the laws of Massachusetts “an unmarried woman is not entitled to be examined for admission as an attorney and counselor of this court.” In the opinion of the Court it is stated that “this being the first application of the kind in Massachusetts, the Court, desirous that it should be fully argued, informed the executive committee of the Bar Association of the city of Boston of the application, and has received elaborate briefs from the petitioner in support of her petition, and from two gentlemen of the bar as _amici curiæ_ in opposition thereto.” The statute under which the application was made provided that, “A citizen of this State ... may, on the recommendation of an attorney, petition the Supreme Judicial or Superior Court to be examined for admission as an attorney, whereupon the Court shall assign a time and place for the examination, and if satisfied with his acquirements and qualifications he shall be admitted.” The Court said that “the word ‘citizen,’ when used in its most common and most comprehensive sense, doubtless includes women; but a woman is not, by virtue of her citizenship, vested by the Constitution of the United States, or by the Constitution of the Commonwealth, with any absolute right, independent of legislation, to take part in the government, either as a voter or as an officer, or to be admitted to practice as an attorney.” (Mass. Supreme Court Rep., vol. cxxxi. p. 376.) The opinion was delivered by Chief Justice Gray. The Legislature, in 1882, passed a statute providing for the admission of women upon the same terms as men. Miss Robinson, now Mrs. Sawtelle, immediately took the examination and was admitted to the Suffolk County Bar. The next year the Legislature extended the powers of women attorneys in an act “to authorize the Governor to appoint women who are attorneys-at-law special commissioners to administer oaths and to take depositions and the acknowledgment of deeds.” This legislation became necessary on account of a decision of the Supreme Court of the State in which it was held that “a woman cannot lawfully be appointed a justice of the peace, or, if formally appointed and commissioned, lawfully exercise any of the functions of the office.” (Mass. Supreme Ct. Rep., vol. cvii. p. 604.) The power “to issue summonses for witnesses” was added in an act of 1889.