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... ntent at http://about.jstor.org/participate--jstor/individuals/early-journal--content. JSTOR is a digital library of academic journals, books, and primary source objects. JSTOR helps people discover, use, and build upon a wide range of content through a powerful research and teaching platform, and preserves this content for future generations. JSTOR is part of ITHAKA, a not--for--profit organization that also includes Ithaka S+R and Portico. For more information about JSTOR, please contact support@jstor.org. 58 VIRGINIA LAW REVIEW committed independently by one of their number in the course of the execution of the common design, but not in furtherance thereof. Powers v. Commonwealth, 110 Ky. 386, 61 S. W. 735, 53 L. R. A. 245. And it would seem that this is the case even though the purpose of the conspiracy be to commit a crime made a felony by statute. See Powers v. Commonwealth, supra. Nor is each of several conspirators liable for a homicide committed by one of them, when pursued, where each is making an individual attempt to escape. See Rex v. White, Russ. & R. C. C. 99. BANKRUPTCY-LIFE INSURANCE-REDEMPTION OF POLICY.-The plaintiff and other creditors filed an involuntary petition in bankruptcy against B., and later B. died. Subsequently B.'s estate was adjudicated bankrupt, and a trustee was appointed. The plaintiff promptly made proof of his claim against the estate, and it was allowed. The bankruptcy court, upon the application of the plaintiff, ordered that his claim be expunged from the list of claims, and this was done accordingly. Still later a dividend was declared and paid, in which dividend the plaintiff did not participate. At the time of his death, B. owned two life insurance policies, the proceeds of which, less their cash surrender value, which had been paid to the trustee, were paid to the defendant, the executrix of the estate. No order for the discharge of the bankrupt was applied for or granted. The plaintiff brought an action to subject the proceeds of the policies to the payment of his debt, claiming that ? 70a (5) of the Bankruptcy Act conferred this right. Held, the plaintiff may recover. Andrews v. Nix, 246 U. S. 273. See NoTES, p. 43. CHATTEL MORTC,AGES--TITLE-LIEN-INCREASE OF DOMESTIC ANIMALS.-alized from the sale thereof. Gannaway v. Tate, 98 Va. 789, 37 S. E. 768. In regard to the status of the Lien Theory in Virginia, as applied to real estate mortgages, see discussion in 5 VA. LAW REV. 205. CONSTITUTIONAL LAW-EX POST FACTO LAWS-STATUTE PROHIBITING POS-SESSION OF INTOXICATING LIQUORS.-The defendant was convicted for the breach of a State statute making it a crime to have in one's possession more than a specified amount of spirituous liquors. He defended on the ground that the liquor so possessed had been acquired after the approval of the law but before, by its terms, it became effective, and that the law could not, therefore,.apply to such liquor. Held, the conviction was constitutional. Barbour v. Georgia, 39 Sup. Ct. 316. Slightly earlier decisions, out of regard for the privileges of the individual, restricted the power of the State in dealing with the possession and handling of intoxicating liquors. Spirituous liquors are "property" within the meaning of the Fourteenth Amendment to the Federal Constitution. municipal ordinance prohibiting the keeping, in certain places, of intoxicating liquors, for any purpose whatever, lawful or unlawful under the State prohibition act, was held to be void, as an unconstitutional extension of the police power of the municipality. The following cases also deny to a state or a municipal corporation the constitutional right to prohibit the keeping of intoxicating liquors by its citizens, regardless of any intention to dispose of them illegally. Titsworth v. State, 2 Okla. Cr. 268, 101 Pac. 288; State v. Gilman, 33 W. Va. 146, 10 S. E. 283; Sullivan v. Oneida, supra: Ex parte Brown, supra. Contra, Delaney v. Plunkett, 146 Ga. 547, 91 S. E. 561. Judicial opinion, however, has been continually changing in the direction of an extension of the States' power in this respect. The general police power of the States has never been delegated to the Federal Government, and is not directly restrained by the Constitution. Barbier v. Connally, 113 U. S. 27. See In re Rahrer, 140 U. S. 545; and United States v. Knight, 156 U. S. 1. It has been held that a State may prohibit the mere possession of game in closed season. Silz v. Hesterberg, 211 U. S. 31; Roth v. State, 51 Ohio 209, 37 N. E. 259,.46 Am. St. Rep. 566. Intoxicating liquors are peculiarly the subject of the exercise of the police power. A state has absolute power to prohibit the manufacture, gift, purchase, sale or intrastate transportation of liquor. Bartemeyer v. Iowa, 18 Wall. 129; Beer Co. v. Massachusetts, 97 U. S. 25; Mugler v. Kansas, 123 U. S. 623; Purity Extract and Tonic Co. v. Lynch, 226 U. S. 192; Clark Distilling Co. v. Western Maryland R. Co., 242 U. S. 311. See Crane v. Campbell, 245 U. S. 304. Since the State has this right, it must have the power to make it effective. When a State, in the exercise of its police power, seeks to suppress an evil, it may adopt such measures, having a reasonable relation to that end, as it may deem necessary in order to make its action effective, even though it may, thereby, render illegal transactions and pursuits which are innocent in alized from the sale thereof. Gannaway v. Tate, 98 Va. 789, 37 S. E. 768. In regard to the status of the Lien Theory in Virginia, as applied to real estate mortgages, see discussion in 5 VA. LAW REV. 205.