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. He must prove, in addition, that the donor had competent and independent advice as to the effect of his act.7 In Post v. Hagan,6 the court said: "Proper independent advice in this connection means that the donor had the preliminary benefit of conferring fully and privately upon the subject of his intended gift with a person who was not only competent to inform him correctly as to its legal effect, but who was furthermore so dissociated from the interests of the donee as to be in a position to advise with the donor impartially and confidently as to the consequences to himself of his proposed benefaction." Applying this rule to our principal case, the decision was inevitable. For there was here no form or semblance of such advice, and the subject-matter of the gift represented about all the property that the donor owned over and above his debts. The public policy upon which such a rule is founded is apparent. It is just and reasonable that it should not be possible for those who, by old age or illness, may be deprived of their mental vigor, to deprive themselves of their means of support, even in the absence of irresistible importunities, unless advised so to do by disinterested and competent parties. It is, therefore, not surprising to find the authorities outside of New Jersey agreeing with such a rule.8 It is submitted that what few cases hold that the receipt of such advice is not necessary, are really cases in which the donor and donee did not stand in a confidental relation at all. The interesting question which arises is as to how much a donor may give, without bringing himself within this rule. The court in our principal case wisely remarks that the question is not so much one of definite fractions, as of practical results. Judge Stephens goes on to say: "I think the practical rule .. . is, that a donor, having barely sufficient property to sustain himself for the rest of his life, shall not irrevocably and without advice, give away so much of it as to leave himself an object of charity." This seems eminently reasonable. P. V. R. M.