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. 498 UNIVERSITY OF PENNSYLVANIA LAW REVIEW 498 UNIVERSITY OF PENNSYLVANIA LAW REVIEW of the Federal government to compel its enforcement. That being the case, the state to which a man had fled might be induced to give him up if he were charged with one crime, and not, if with another. Now if, after being returned, the defendant were to be tried upon a different charge, that would be extremely bad faith with the surrendering state, as well as with the prisoner. In conclusion, it is interesting to note, in this connection, that if a man is tricked into the jurisdiction, or is kidnapped and forcibly carried back, he, nevertheless, has no defense on that score.12 J. F. N. DAMAGES-LOSS OF WIFE'S SERVICES-PROXIMATE CAUSE- The Court of Appeals of New York, held in a recent decision' that a husband may maintain an action for damages for the physical illness of his wife, consequent upon mental anguish caused by the publication of words reflecting upon her character, which were libelous per se. The court proceeded upon the ground that-the rights of the husband were co-extensive with those of the wife; that if she could recover damages for such injuries, he could also. The primary inquiry of the court was as to the measure of damages recoverable by the wife if she had brought suit instead of her husband. Earlier decisions in New York hold that proof of mental distress and physical illness resulting therefrom will not give a right of recovery either to the person libeled2 or her husband3 where the alleged defamatory matter is not libelous per se. This view seems to represent the trend of modern authority4 and to be correct on principle. The gist of the action for defamation is the injury to the plaintiff's reputation; mental distress and sickness do not prove the fact of such injury, but are simply the results of an apprehension of injury. Baron Bramwell said in Alsop v. Alsop:s . . the law holds that bodily illness is not the natural nor the ordinary consequence of speaking slanderous words. Therefore, on the ground that the damage here alleged is not the natural 12 Mahon v. Justice, 127 U. S. 700 (1887).