spection and equipment of the boat, he may be relieved under the statute, though the agent may in some particulars be negligent. In the case of The Annie Faxon, 21 C. C. A. 306, 44 U. S. App. 591, 75 Fed. 312, it was held that privity or knowledge of a defect in a steamboat boiler could not be imputed to the owner if the defect was not apparent, and was not of such a character as to be detected by the inspection of an unskilled person, and he had in good faith employed a competent person to make the inspection. The same case held that, if the government inspectors called to make an examination of the vessel failed to perform their duty, knowledge of their defective in spection could not be imputed to the owner if he had delegated the matter of the in spection to a competent employe. But where the shipowner himself undertook to examine the vessel, and failed to use proper care in doing so, it was held, in The Re public, 9 C. C. A. 386, 20 U. S. App. 561, 61 Fed. 109, that he could not claim that a loss occurring from a defective* condition which he failed to discover occurred with out his privity or knowledge. Where the owner of the vessel is a corporation it is held, in Craig тр. Continental Ins. Co., 141 Г. S. 638, 35!.. ed. 886. Sup. Ct. Rep. 97, that the privity or knowledge referred to in the statute must be that of the man aging officers of the corporation. The above cases give the substance of the law known as the limited liability law with respect to the shipowner's liability for the loss of passengers. This law. as above shown, ap plies to the loss of life as well as to other losses or injuries. Hut there is another act of Congress which needs to be considered on this subject. It is the steamboat inspection act of February 28, 1871. Section 43 of that act provides that for damage to a passenger through any failure to comply with the re quirements of that statute, or because of known defects or imperfections in steering apparatus or hull, the owner and master, as well as the vessel, "shall be liable to each
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and every person so injured" to the full amount of the damage. This language, strictly construed, would not seem to give a right of action for death of a passenger to his personal representatives, but it seems to be assumed without question in The Annie Faxon, 21 C. C. A. 366, 44 U. S. App. 591, 75 Fed. 312. that this provision does govern cases of death as well as those of personal injuries. That case does clearly hold, however, that the owner's failure to comply with the inspection law may defeat bis right to the limitation of liability. The Supreme Court of the United States, in Butler v. Boston & S. S. S. Co. 130 U. S. 527, 32 L. ed. 1017, 9 Sup. Ct. Rep. 612, left room for a doubt whether a failure to comply strictly with every requirement of this statute would necessarily defeat the owner's claim to a limitation of liability. In that case it held that under Sec. 43 of this act he could not have the benefit of limited liability if the injury or loss occurred through his fault. This seems to suggest 'the possibility that there might be in some instances a lack of strict compliance with the statute which would not be deemed his fault. The act of Congress of June 26, 1884. Sec. 18. which provides for the apportion ment of the debts and liabilities to the in dividual owners, has been considered in con nection with the inspection law, but was held in The Annie Faxon, 21 С. С. A. 366, 44 U. S. App. 591, 75 Fed. 312, to leave that act unrepealed. "THE Legal Position of Trade Unions," in England, is thus summed up by A. Ure in The Juridical Review (London) : The results of the foregoing survey of the present state of the law relating to tradeunions may be summarized in a few sen tences. A trade union can with impunity communicate a fact to a workman, and wait about his doors to do it, but may not exer cise upon him the art of peaceful persuasion however bland its accents may be, and how ever transitory the workmen's position may be. A gangway from ship to shore is as
