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 545 545 W. 468, cited by the court in the principal case there was evidence of the existence of minerals in the land at the time the court held them to be an estate. "There may be two distinct and separate freeholds in the same parcel of land, if it contain minerals, quarries of stone, and the like, the one embracing the surface, the other the mines." 2 WASH. REAL PROP., Ed. 4, p. 375. At least one solution is possible. The use of the term undiscovered minerals presupposes the existence of minerals in the land that are susceptible of discovery. To give this construction to the term, however, reads into the case the fact that there were minerals in the land, of which fact the court expressly says there is no evidence. The purpose of the statutory notice is undoubtedly to give all those claiming an interest in the land under the last recorded deed an opportunity to protect their interests. To hold that the holder of the reservation is entitled to notice under the statute on the ground that he is still the "grantee in the last recorded deed" as to minerals is one thing, but to hold that undiscovered minerals constitute an estate in land where there is no evidence of the existence of minerals in the land is another, and was perhaps somewhat beside the point necessary to be decided in the case. However, the principle of the case is important, especially to the Northern Peninsula of Michigan, where many valuable mines and ore deposits have in late years been discovered on lands, the taxes on which have been neglected, but which lands, owing to their location in the so-called mineral belt, had been conveyed in most instances by the patentees, subject to mineral reservations. (BAINBRIDGE'S LAWS OF MINES & MINERALS, p. 4.) The importance of serving notice on the owners of mineral rights under such reservations, whether minerals have been discovered on the lands or not, is shown by the decision in the principal case. Until notice is served upon each part owner, and the statutory proof thereof made and filed, the right to redemption remains to all. White v. Shaw, 150 Mich. 270, 114 N. W. 210; Dolph v. Norton, 158 Mich. 417, 123 N. W. I3.