Known as the Early Journal Content, this set of works include research articles, news, letters, and other writings published in more than 200 of the oldest leading academic journals. The works date from the mid--seventeenth to the early twentieth centuries. We encourage people to read and share the Early Journal Content openly and to tell others that this resource exists. People may post this content online or redistribute in any way for non--commercial purposes. Read more about Early Journal

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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. RECENT IMPORTANT DECISIONS RECENT IMPORTANT DECISIONS which had a peculiarly historical origin in cases of trespass by domestic animals (see Tillett v. Ward, L. R. IO Q. B. D. I7), which later was extended to apply to the use of land (Rylands v. Fletcher, supra), and which was finally extended in its application to the use of inanimate chattels (Jones v. Festiniog Ry., L. R. 3 Q. B. 733 and Powell v. Fall L. R. 5 Q. B. 597); a doctrine which, in its extended application, "would impose a penalty upon efforts, made in a reasonable, skilful, and careful manner, to rise above a condition of barbarism." Doe, J., in Brownl v. Collins, 53 N. H. 442. In a case similar to the principal one the Supreme Court of Tennessee said that "the degree of care required of one * * * with a steam thresher, in respect to setting fires, is the same as that devolved upon railway companies in the use of their engines." Martin v. McCrary, 115 Tenn. 316; I L. R. A. (N. S.) 530. That duty as laid down by the same court in a prior case is that "a degree of care and prudence commensurate with the danger to which property is exposed by them" must be used. "And when they have them properly constructed and equipped with spark arresters and appliances of the latest and most approved character to prevent the escape of coals and cinders, in good repair, and carefully and skillfully handled, * * *they are not liable for property unavoidably destroyed by escaping sparks and cinders." Loui.ville & N. Ry. v. Fort, II2 Tenn. 432. In this matter the Tennessee court exemplifies the weight of authority in America which asserts, while the English courts repudiate, a hornbook principle of the common law, viz., that "blame must be imputable as a ground of responsibility for damage proceeding from a lawful act." Marshall v. Welwood, 38 N. J. L. 339.