The American Reports. Containing all Decisions of General Interest decided in the Courts of last resort of the several States, with Notes and References. By Isaac Grant Thompson. Vol. I. Including cases decided in the Courts of Maryland, Massachusetts, Wisconsin, Iowa, Vermont, Pennsylvania and New York. Albany, John D. Parsons, Jr., 1871.

It is said that when Justinian came to the throne of the Roman Empire, the laws and legal opinions filled so many volumes that no fortune could purchase and no capacity could digest them. Were books as expensive in our days then, the same remark might, with strict propriety, be applied to the reports of decisions of the courts of this country. Over two thousand volumes of these reports are already extant, and that number is being increased annually in a sort of arithmetical proportion.

Although the decisions of the courts of last resort of other states, on questions of general law, are of almost as much importance to a lawyer as the decisions of his own state, we doubt if there be a score of lawyers in the country that attempt to keep complete sets of even a moiety of the reports of other states.

The necessity of some plan by which these decisions of general value could be separated from local and practice cases, and made available to the profession, has for some time been fully acknowledged, but the difficulty has been to fix upon a feasible plan. We have heretofore noticed in these pages the plan of the Hon. T. F. Withrow, late state reporter of Iowa, and which was then thought to be a possible solution of the problem. He proposed the organization of state associations, and of a council of reporters, consisting of one representative from each state association, the duty of which should be to gather and report the general cases. The plan was certainly cumbersome, and, to our thinking, impracticable, in view of the present disorganized state of the profession.

The "American Reports," the first volume of which is before us, is another attempt at a solution of the difficulty, and, unless we very much mistake, a very complete and satisfactory solution it is. The plan has certainly the merit of simplicity. It is briefly this: to gather together every case of general value appearing in the current reports of every state in the union. It is in no wise retrospective, and does not contemplate reporting any case save those hereafter appearing in the several state reports. The cases of general value in most of the state reports are not numerous, averaging, probably, not over twelve. It will, therefore, be no very difficult matter to include the useful from every state in the three volumes which are promised by the publisher to be the limit of the number per year. A few of the states, New York, Massachusetts and Pennsylvania, will furnish a much larger number of cases, since the questions coming before their courts probably exceed in variety and importance those arising before the courts of any ten of the other states in the union.

But, however good the plan of the "American Reports," their real value and utility must depend mainly on the judgment and skill with which that plan is carried out. To select all and only the cases that are of general importance from such a mass of practice and local cases is a matter by no means easy; yet on its successful accomplishment is pivoted the essential merit of the series. Inasmuch as the name of the editor of this journal appears as the reporter of these reports, it will hardly be expected that we should express our opinion upon the execution of this volume. We will notice the fact, however, that there is given no table of cases cited, an omission that we hope, and, we may add, believe, will not occur again.

The mechanical execution of the book is excellent. The type is clear, the paper good, and the binding much better than that of the average reports.

Reports of Cases in Law and Equity, determined in the Supreme Court of the State of New York. By Oliver L. Barbour, LL.D. Vol. LVII. Albany, 1871. W. C. Little & Co.

Reports of adjudicated cases are constantly increasing in importance, not only as authoritative expositions of what the common law is, but as declaratory of the precise meaning of the statute law. Much fault has been found of late with the number of volumes issued by the reporters, and various plans have been suggested to remedy the alleged evil. It is unquestionably true that the bench and bar are not suffering at present from a deficiency in quantity of legal literature of this character. The quality may not always be the best, but we suppose the reporters can excuse themselves by saying that they furnish the best there is. But wherever the fault may be, the increased number of reports and volumes is working an injury both to the legal profession and to the public at large. Upon the one it imposes increased expense and labor, and upon the other inflicts all the disadvantages that can arise from an uncertain and conflicting code, made inaccessible to the people by reason of its enormous size. It is said that a Roman emperor tried to keep the public ignorant of the law by placing the written tablet, containing the decrees of the senate, so high that the words could not be distinguished by one standing on the ground. The reporters of our nineteenth century have discovered a more effectual way of accomplishing the same purpose, so that not only the people, but the lawyers and judges, too, long since gave up even attempting to know all the decrees of the various bodies who practically manufacture the laws of the land.

The evil effects of indiscriminate reporting were felt in England many years ago, and were to a great extent remedied, and Great Britian has to-day a system of law reporting which satisfies every one. Attempts have been made in this country, by constitutional and legislative enactment, to meet the complaints of the profession, but these efforts have so far resulted only in advantage to the reporters and publishers. In some of the states reporting consists merely of getting together all the opinions delivered and printing them with head notes. Cases involving facts, only, or some elementary rule of law, are given equal dignity with those in which important legal principles are determined. The state of New York has not been affected by this style of reporting as yet, but we must confess that the business is overdone even here. There are being issued at the present time some nine or ten different series of reports in this state, besides which numerous cases appear in the LAW JOURNAL and New York Transcript. Six of these series are confined to specific courts, one to criminal decisions, while the others report cases involving practice points. The criminal and practice cases are taken from all the courts. The supreme court, however, furnishes a very large percentage of the pabulum of the last-named reports, and has also two sets of its own. Thus there are four different

series of law reports in the pages of which the decisions of this court appear.

As the reporters act independently of each other, it frequently occurs that the same cases appear in two, and sometimes in three, different places. And this is not always accidental, as the second appearance is sometimes too long after the first to admit of such an idea. Mr. Barbour may have some excuse for this, as it is his duty to furnish all important decisions of his own court without reference to their appearance elsewhere, and he has never, as has occurred with other reporters, reproduced decisions previously published in his own vol

umes.

It has always seemed to us, that if in reporting the decisions of our supreme court these rules were observed, the reports would be more valuable and of greater authority than they now are: (1) To report only the decisions of the general terms, and when a decision is made by a divided court and an appeal is taken, not to report the decision pending the appeal. (2) To publish the points of counsel only when they add value to the opinion and wherever it can be done in an abbreviated form. (3) To give all the opinions of importance delivered at all the general terms as early after they are rendered as possible. In the volume before us little care seems to have been taken from what source the decisions come, whether they had been overruled or no, or when they were delivered. We have general and special term decisions intermingled; cases reversed in the court of appeals, in which the decision of reversal has been published for months, and cases decided nearly seven years ago (since which time Mr. Barbour has issued seventeen volumes). This volume seems to be an omnium gatherum of the opinions the reporter had left over, and much that is of no importance has found place in its pages. Decisions made years back and elsewhere reported occur in several instances. The abstracting is, of course, well done; somewhat prolix, perhaps, but still hardly to be improved upon.

We hope the next volume will show a better selection of opinions than the present, and will be confined to cases argued and determined since the new judiciary act went into operation. The present organization of the supreme court is working well, and decisions are less conflicting than heretofore. From those decisions a series of reports can be made up, not less valuable than those of any other tribunal. Mr. Barbour has experience in the matter, and is capable of doing the work well. If he will do his best there will be no need for the appointment of an official reporter.

-Our contemporary, the United States Jurist, grows decidedly better each month. The March number comes to us enlarged, four pages having been added, making in all twelve pages of reading matter per month. One of its most valuable features is its digest of the decisions in the United States courts for 1870, which is exceedingly well prepared. Considerable space is devoted to the legal intelligence of the month.

TERMS OF COURT FOR MARCH.
SPECIAL TERMS AND CIRCUITS.

3d Monday, circuit and oyer and terminer, Westchester, Gilbert. 3d Monday, circuit and oyer and terminer, Schenectady, Bockes.

3d Tuesday, special term, Jefferson, Mullin. 4th Monday, special term, White Plains, Gilbert. 4th Monday, circuit and oyer and terminer, Yates, Johnson.

4th Monday, circuit and oyer and terminer, Herkimer. 4th Monday, special term, Erie, Talcott.

Last Monday, circuit and oyer and terminer, Tompkins, Murray.

Last Monday, special term, Monroe, Dwight.
Last Tuesday, special term, Albany, Ingalls.
Last Tuesday, special term, Cortland, Parker.

LEGAL NEWS.

The Richmond courts admitted their first colored lawyer to practice last week.

John H. Oliver, the leading member of the Lehigh county, Pa., bar, died on the 11th inst., after an illness of three weeks, of typhoid fever.

A California jury, in a murder trial the other day, determined the verdict by lot, and brought in the accused man guilty. He has been granted a new trial.

The defendant in a breach of promise case in Iowa, put in a plea that "he was in earnest about marrying the girl, until he got the rheumatism."

Chief Justice Mason, of Nebraska, has delivered an opinion against negroes sitting as jurors in that state. He thinks the constitutional amendments give the negroes certain rights, but impose no duties upon them. A committee of the North Carolina house of representatives are to investigate certain charges made against Judge E. W. Jones, of the second judicial district of the

state.

Congress has passed a resolution authorizing the president to appoint a commissioner to attend an international congress on penitentiary and reformatory discipline, proposed to be held in Europe.

The case of Virginia v. West Virginia —a suit in which the former sought to recover the counties of Berkeley and Jefferson, alleged to have been ceded to it by the latter several years ago, and which has been twice argued has been decided by the United States supreme court in favor of West Virginia. Mr. Justice Miller delivered the opinion of the majority of the court, holding that the cession was, in two respects, regular, and that Virginia could not now question it or impeach the action of its state officers in the premises. Justices Davis, Clifford, and Field dissented.

Hon. Horace Hawes, the first American judge who held court in San Francisco, and one of the wealthiest citizens of California, died on the 12th inst. Mr. Hawes left property valued at nearly $2,000,000 so tied up as to make it useless to his widow and child. Just before dying he sent a message to the courts, saying that he had always disapproved of adjournments out of respect to the memory of deceased members of the bar, and requested that no adjournment be allowed in his case. It is believed that his will will be set aside on the ground of insanity, and injustice to his family.

At the meeting of the New York Genealogical Society in Mott Memorial rooms, on Saturday evening last, Dr. C. B. Moore read a paper on two noted individuals, remarkable for the number of their lawsuits. One of them, James Jackson, was a Friend and a man of peace. When he saw a piece of land that he thought he would like to own he took an acquaintance with him, who immediately became an actual occupant, and from this individual he would take his title. Titles in those days were not well settled, and in time Mr. Jackson became a troublesome neighbor. It was necessary, at last, that` some one should keep a watch on his movements. John Stiles constituted himself the natural enemy of Jackson, and shadowed him wherever he went. If Jackson carried a "possessor" to some favorable spot, Stiles met him and shouldered him off, or pushed him by main force to the common road. Then commenced an action for ejectment, and Stiles called upon the original possessor to defend the suit. About 700 of these cases, in which legal points of importance in the acquisition of titles were decided, have been reported in New York reports alone. The speaker regretted that he could find no biographical sketch of either of the parties, notwithstanding their patronage of the law. We read this cum grano salis.

The Albany Law Journal.

ALBANY, MARCH 25, 1871.

NOTES FROM THE LIFE OF RUFUS CHOATE. "Lives of great men all remind us," and so may some of the processes by which men have achieved greatness. The following notes from a fragmentary diary of Rufus Choate, show us something of the secret of his success.

"June 23, 1844. It is necessary to reconstruct a life at home; life professional and yet preparatory; educational, in reference to other than professional life. In this scheme the first resolution must be to do whatever business I can find to do; tot vir maximo conatu as for my daily bread. To enable me to do this, I must revive and advance the faded memory of the law; and I can devise no better method than that of last summer-the preparation of a careful brief, on every case in Metcalf's last volume, of an argument in support of the decision. In preparing this brief, law, logic, eloquence, must be studied and blended together. The airy phrase, the turn of real reply, are to be sought and written out. I may embody in a commonplace the principles acquired; and I shall particularly strive to become as familiar with the last cases of the English and federal benches, at least, and, if possible, of those of New York, Maine and New Hampshire, as of our own. I have lost the whole course of those adjudications for some years. These studies, and this practice, for the law.

"I advance to plans of different studies and to the training for a different usefulness and a more conspicuous exertion. To avoid a hurtful diffusion of myself over too wide and various a space, laboriose nihil agens, I at once confine my rhetorical exercitations within strict and impassable limits. I propose to translate Cicero's Cataline Orations, or as many as I can, beginning with the first, with notes. The object is: 1st. The matter and manner of a great master of speech. 2d. English debating style, and words. 3d. The investigation of the truth of a remarkable portion of history. All the helps are near me. I shall turn the orator, as nearly as I can, into a debater statesman of this day, in parliament and in congress. "July 16. The gift of an interleaved digest of Massachusetts cases suggests and renders practicable a plan of reviewing and reviving the law. I shall add the fifth volume of Metcalf to the digest as it stands, and, in doing so, advert to the whole series of decisions. This will not interfere with my purpose of making a frequent brief on legal theses. A trial of myself in that way, yesterday, encouraged me to suppose I can recall and advance my law. I am sure I have hit on the right mode of study by digest and brief; and I feel in the resolution a revival of zeal, fondness and ability to work.

"July 17. There is a pleasure beyond expression in revising, re-arranging and extending my knowledge of the law. The effort to do so is imperatively prescribed by the necessities and proprieties of my circumstances; but it is a delightful effort. I record some of the uses to which I try to make it subservi

ent, and some of the methods on which I conduct it. My first business is obviously to apprehend the exact point of each new case which I study, to apprehend and to enunciate it precisely-neither too largely nor too narrowly-accurately, justly. This necessarily and perpetually exercises and trains the mind, aud prevents inertness, dullness of edge. This done, I arrange the new truth, or old truth, or whatever it be, in a system of legal arrangement, for which purpose I abide by Blackstone, to which I turn daily, and which I seek more and more indelibly to impress on my memory. Then I advance to the question of the law of the new decision, its conformity with standards of legal truth, with the statute it interprets, the cases on which it reposes, the principles by which it is defended by the court, the law, the question of whether the case is law or not. This leads to a history of the point, a review of the adjudications, a comparison of the judgment and argument, with the criteria of legal truth. More thought, produced and improved by more writing and more attention to last cases of English and our best reports, are wanting still. I seem to myself to think it is within my competence to be master of the law, as an administrative science. But let me always ask at the end of an investigation, can this law be reformed? How? Why? Why not? Cui bono the attempt?

"A charm of the study of law is the sensation of advance, of certainty, of 'having apprehended,' or being in a progression toward a complete apprehension of a distinct department and body of knowledge. How can this charm be found in other acquisitions? How can I hit on some other field or department of knowledge which I may hope to master; in which I can feel that I am making progress; the collateral and contemporaneous study of which may rest, refresh, and liberalize me, yet not leave mere transient impressions, phrases, tincture; but a body of digested truths and an improved understanding, and a superiority to others in useful attainment, giving snatches of time, minutes, and parts of hours, to Cicero, Homer, Burke and Milton, to language and literature? I think I see in the politics of my own country, in the practical polities of my country, a department of thought and study, and a field of advancement, which may divide my time and enhance my pleasure and improvement, with an efficacy of useful results equal to the law." The following letter is in answer to one asking Mr. Choate as to a course of reading preparatory to the law:

BOSTON, January 2, 1841.

Dear Sir, I should have been very happy to answer your letter before this, but a succession of engagements, some of them of a painful kind, have made it impossible. Even now I can do very little more than congratulate you on being able to spend a year at such a place, and to suggest that very general “macte virtute," which serves only to express good wishes without doing any thing to help realize them. I should be embarrassed, if I were in your situation, to know exactly what to do. The study of a profession is a prescribed and necessary course; that of general literature, or of literature preparatory to our or to any profession, is, on the other hand, so limitless- 80 indeterminate-so much a matter of taste, it depends so much on the intellectual and moral traits of the student, what he needs and what he ought to shun, that an educated young man can really judge better for himself than another for him.

As immediately preparatory to the study of the law, I should follow the usual suggestion to review, thoroughly, English history, constitutional history in Hallam par ticularly, and American constitutional and civil history in Pitkin and Story. Rutherford's Institutes and the best course of moral philosophy you can find, will be very valuable introductory consolidating matter.

Aristotle's Politics, and all of Edmund Burke's works, and all of Cicero's works, would form an admirable course of reading, "a library of eloquence and reason," to form the sentiments and polish the tastes, and fertilize and enlarge the mind of a young man aspiring to be a lawyer and statesman. Cicero and Burke I would know by heart; both superlatively great-the latter the greatest, living in a later age, belonging to the modern mind and genius, though the former had more power over an audience both knew every thing.

I would read every day one page, at least-more, if you

can-in some fine English writer, solely for elegant style and expression. William Pinckney said to a friend of mine, "he never read a fine sentence in any author without committing it to memory." The result was decidedly the most splendid and most powerful English spoken style I ever heard.

I am ashamed to have written so hurriedly in the midst of a trial, but I preferred it to longer silence. Accept my best wishes, and assure yourself I am

Very truly yours,

R. CHOATE.

REPORTS AND REPORTERS.

The following article, published some time since in the English Law Magazine, is worthy of consideration in this day and land of many reporters. Although judgments are, here, seldom delivered orally as they were and still frequently are in England, the essential qualifications of a reporter are the same.

The duties and labors of a reporter are appreciated for the most part, even by those who reap the greatest advantage from his exertions, at a very low rate. Nobody within the pale of the legal profession doubts that he is a useful person; but that is the highest honor that is generally awarded to him; he is looked upon as a sort of mechanic, or perhaps that is even too high a title, for it is supposed to imply something like the possession of genius and science. Let us rather say (adopting these ideas of others), a mere operative, a legal mason or tailor, who works up the materials supplied by others in order to meet the demands of the intelligent public. He is, no doubt, a very useful person, indispensable, in fact, to the existence of society, and society gratefully admits in the abstract that they are under vast obligations to him; but nobody (that is of the class of thinkers we are speaking of) ever dreams of looking upon him in any other light; and as to be useful is not the way to be distinguished, he does not accordingly rank very high in public estimation. It is admitted that he goes through a great deal of drudgery, but it is taken for granted that he is amply repaid for it by his publisher, if, indeed, the matter is ever thought of at all. He is ranked pretty much upon the level of a digest maker; though as an obiter dictum, we beg to say we think that class of writers very much underrated; we are not now alluding to such work as Comyn's Digest, in the compilation of which great learning, research and judgment are, by universal admission, brought to bear; but we speak of such works as marrison Ladez, x Jeremy's Digest, the

merest compilations of marginal notes, and we now avow that we think the arranger of such a work, always supposing it to be well performed, deserves great credit for his pains. For, as Dr. Johnson might have said, to render the services of others more available, to collect widely scattered materials and arrange them in lucid order, and from a rude and indigested mass to form a harmonious and symmetrical fabric, are, surely, objects not wholly unworthy of a mind even of the higher order.

But to return to our reporter. He, at any rate, it may be said, does not require any but the humblest capacity to perform his functions. A mere transcriber of the opinions of others, he occupies the very lowest grade in the scale of professional utility- what the copyist is to the musician, or the printer to the author, he is to "the reverend judges and sages of the law" (as Lord Coke delights to call the learned administrators of justice). Without his aid, indeed, much that is valuable would be lost to the world, but the aid is all that he contributes; every thing original, both of thought and execution, that is to be found in his labors, is the emanation of other minds. In perusing a reported case it is the counsel who argue and the judges who decide who are present to one's imagination; who ever bestows a thought on the humble reporter? Their names may, indeed, be as familiar in our mouth as household words, but this familiarity is too usually attended by its well-known offspring. It is true, indeed, that your reporter in this way enjoys a sort of fame, which, per ora volat, in more than the usual manner, but his fame is merely nominal; his name is his immortal part. Indeed, our abstract idea of a reporter is rather that of a book than of a man. Who ever thinks of Bingham, for example, as a human being? There he is, alive and well, and efficiently discharging his duties as a police magis trate, but he is never present to our mind's eye in that character: if the name is mentioned, an octavo volume, naturally of a pale complexion, but sallowed and embrowned by time and use, presents itself to the imagination. Indeed, the word "Bingham" by itself, without a numeral affixed to it, such as "2" or "8 Bingham," is almost an incomplete idea. We might also doubt whether the gentleman himself, with whose good name we may, perhaps, be supposed to be making rather too free, has not, from long and frequent use, so accustomed to regard his identity in this light, that probably if a friend should say to him, “Bingham, I want you," he would reply, "what volume?" or "old or new series?"

Making allowances, however, for a somewhat transatlantic view of exaggeration into which we have fallen, we think it will not be denied that there is a great deal of substantial truth in what we have advanced, and that a reporter's labors do not generally obtain for him any very large share of consideration. We own, ourselves, that we think they are entitled to a much larger portion, and that the reporter, himself, is hardly and unjustly dealt with by those who consider him only in the light of a useful workman; and we shall endeavor, briefly, to point out the nature and degree of the capabilities, which, in our humble opinion, are requisite for the due performance of his task.

Of the amount of labor required, it is not necessary

intolerable nuisance if he did furnish it) a full transcript of all that is said in court; what he is expected to do is to give an accurate abstract of it, showing all the material facts, the course of the argument, and the reasons on which the judgment of the court is founded. The making up of the marginal notes is also a very important and not very easy matter. It ought to set forth the principle on which the case is decided, unless, indeed, it be one of those which is so universally ac

In the first place, we hold it to be one of the principal requisites of a good reporter, that he should be a good lawyer, otherwise he will not be able to understand one-half of what is said in court, where, of necessity, first principles are very rarely discussed, and are scarcely more than alluded to; and he will consequently find his notes, when he comes to write them out, of little or no service to him. The practice of reporting, at least of taking notes, and afterward reducing them into shape of a report, is undoubtedly of the greatest advantage to the student; it would be a useful assistance even to many a "practicing barrister of five years' standing," by reason of the habit it generates of forcing attention to what is going on in court, of afterward searching and verifying authorities, or of arranging arguments on the grounds of the judgment of the court, in a clear and systematic order. A habit of this kind, though it ought not to supersede the regular perusal of books, will be found a most valuable auxiliary to that method of study; but the profession have a right to expect that they shall be furnished with something better than the mere exercises of a tyro, or, at any rate-which is of more consequence - they will not encourage such effusions; as, in the present over-crowded state of the bar, it is not likely there should be any want of persons both able and willing to undertake the business of reporting.

But the real severity of the reporter's duties commences at his own chambers. He has first to obtain and examine the briefs and papers in each case, in order that he may be able to give a correct statement of the pleadings or facts upon which the decision rests; he has to refer to the authorities cited on either side, and these he ought, unless he be previously well acquainted with them, carefully to peruse, not contenting himself with the mere reading of the marginal notes, in order to see how far the case referred to bears out the proposition for which it has been cited; and whether there may not be some portions of it which would vary or qualify its applicability to the case in hand: and this is more particularly necessary with reference to the older reports, in citing which, it will be found to be merely obiter dicta, or, perhaps, even propositions advanced by counsel arguendo. The reporter will then have to write out the arguments and judgments from his notes, which is, perhaps, the most difficult-certainly the most delicate part of his labors; he will have to select, to arrange, to condense, to polish. The best argument or oral judgment ever delivered does but read uncouthly when presented with verbal accuracy through the medium of a short-hand writer's notes. The reporter does not profess to furnish (what would be, indeed, an

court of law; and this principle it would be the safest plan to give, where it is possible, in the very language in which it has been propounded by the judge in the case; and then a concise statement of the facts of the case, showing the application of such principle; and to these may be added, when occasion requires, under a semble or a query, any important point which has been discussed, though not absolutely decided in the case, as also any strong and marked dicta of the judges, tending to show the inclination of their minds on points which may arise in other cases, and which are not actually determined in the case in hand. Great care should be taken, however, never to confound such dicta with the points really decided; for the former, though they may be of weight and value in the formation of future opinions, can never, however learned their author, or however well considered they may have been, be regarded as authorities, for, as they are not opinions delivered on the points really before the court, they are incapable of being revised. To perform these duties properly, it will be found that considerable skill and judgment, as well as industry and legal knowledge, are requisite; and we think we have sufficiently shown that a task, calling for such attributes for its performance, is not one that can be successfully undertaken by persons of slight capacity. With regard to the style or manner of reporting, that is a matter which depends a good deal on the taste of the individual reporter, and in some measure of the age in which he lives. We may find some future occasion, to advert briefly to the characteristics of the principal labors in this field of jurisprudence; but we want here only to observe, that the two great errors to avoid are too close conciseness and too large diffuseness. The happy course lies midway. Of the two evils, perhaps the greater is the first mentioned, because it often leads to the omission of matter that is indispensable to the intelligibility of the report. the other hand, nothing is more wearisome than a long protracted report, where unnecessary pleadings and facts are stated at length; and perhaps repeated in different parts of the case, where the arguments of counsel and the judgment of the court are given with a verbose minuteness, and where the authorities cited in court are set out verbatim, so that if such a course were universally adopted, our law works would, in a few years, be filled with the same matter repeated over and over again. A report of this nature is sometimes as inefficient as those of the other class, for the mind gets wearied with traveling over such a desert of verbiage, and becomes unable to select for itself passages to which its attention should be principally directed. It would be invidious to mention names, but we could certainly point out one reporter of the present day who falls grievously into this error, and whose reports have a strong flavor of the short-hand

On