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 RECENT IMPORTANT DECISIONS U. S. 91. But ordinances excluding ifrom boulevards, etc., business occupations which are not noxious in their nature and restricting building thereon to residence uses only are void. 2 DILON, MUNIC. CORP. (5th ed.) Io6o; St. Louis v. Dorr, I45 Mo. 466; Commonwealth v. Boston Advertising Co., I88 Mass. 348, 69 L. R. A. 817. The law on this subject is in process of development, and it is believed by many writers that the "increased aesthetic sentiment" will eventually cause such regulations to be recognized as valid. 20 HARV. L. REV. 35; 13 BENCH & BAR IO; Eubank v. City of Richmond, IIo Va. 749, 67 S. ,E. 376. NEGLIGENCEi-RULE OF RYLANDS v. FLETCHER.-The plaintiff occupied the second floor of a building leased from the defendant. On the third floor was a lavatory under defendant's control, and used by all of the tenants of the building. During the night, a third person stopped up the drain so that the lavatory overflowed and plaintiff's goods were damaged. No negligence on the part of the landlord was shown. Held, that defendant was not liable. Richards v. Lothian (I913) 82 L. J. P. C. 42. It was held that this case did not come within the rule as laid down in Rylands v. Fletcher, 37 L. J. Ex. 161, that the person who, for his own purposes, brings on his lands and keeps there anything likely to do mischief if it escapes, must keep it at fhis peril. The court followed the dictum in Nichols v. Marsland, 46 L. J. Ex. 174, and the case of Box v. Jubb, 48 L. J. Ex. 417, which latter case cited the dictum of the former as law. This dictum was to the effect that the malicious act of a third person was to be taken, together with an act of God or vis major, as an exception to the doctrine Sic utere tuo ut alienum non laedas. It was pointed out that only when other than ordinary use was made of property did Rylands v. Fletcher control, that bringing water into a building for lavatory purposes is not such a use, and that in case of such ordinary use as this, negligence on the part of the landlord must be shown. The law in the United States has followed the English cases. Becker v. Bullowa, 73 N. Y. Supp. 944; Marshall v. Cohen, 44 Ga. 489. In Rosenfield v. Newman, 59 Mjinn. I56, a case similar to the principal case, it was held that the landlord is not liable when the damage is the result of a stranger's negligence. The case is decided on principle and without reliance on authority. Kenney v. Barnes, 67 Mich. 336, holds that the landlord is not liable for the act of a third person. In that case, the landlord had no control over the lavatory, and the case is decided on that ground and without supporting authority. While the cases in the United States on the point reach the same conclusion as the English cases, they do not place their finding on the ground, as does the principal case, that the act of a third person is an exception to the maxim above stated. This is doubtless due to the fact that the English courts are bound by Rylands v. Fletcher supra, while the courts of the United States have never followed that case to its full length. PARTY-WAILS-RIGHT TO COMPENSATION FOR Us.--The charter of the