Bills and Notes. Signing Checks in Blank. Liability. 125 N. Y. Supp., 94
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... out Early Journal Content 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 firstname.lastname@example.org. YALE LAW JOURNAL YALE LAW JOURNAL YALE LAW JOURNAL RECENT CASES ARSON-ACTS CONSTITUTING.-STATE V. MARTIN, 127 N. W., 896 (NEBR.).-Held, that a tenant who wilfully and maliciously sets fire to and burns a storehouse, the property of his landlord of which the tenant is in possession, is guilty of arson, as defined in section 54 of the criminal code. The common law is that arson is an offense against the possession rather than the property itself, and one who is in the possession and actual occupancy under a lease of the house alleged to have been burned by him, cannot be guilty of arson. State v. Young, I39 Ala., 136. This is supported by the case of Allen v. State, Io Ohio St., 287, in which it is distinctly said that nothing is more firmly settled by authority than that a tenant who burns the building of which he is in possession, is not guilty of arson. But this common law rule has been superseded by statute and in the codes by the doctrine that a tenant may commit arson by burning his own dwelling house. State v. Moore, 6I Mo., 276. In the case of Lipschitz v. 'eople, 25 Colo., 261, it is said that the burning of a building belonging to another, but occupied by the party who burns it, is arson. The modern rule is that one in possession of a house as tenant who wilfully burns it, is guilty of arson. Kelley v. State, 70 S. W., 20; Shepherd v. People, I9 N. Y., 537; Garret v. State, Iog Ind., 527. ATTORNEY AND CLIENT-NEGLIGENCE OF ATTORNEY-ACTIONS-PLEAD-ING.-FRENCH ET AL. V. ARMSTRONG, 76 ATL. REP., 336 (N. J.).-Held, that in a declaration against an attorney for negligence, it need not be averred that his fees were paid.