Seymour, Id. 348: Cawood Patent, 94 U. S. 695; Rubber Co. v. Goodyear, 9 Wall. 788: Parks v. Booth, 102 U. S. 96: Silsby v. Foote, 20 How. 386; Hendric v. Sayles, 98 U. S. 546; Eureka Co. v. Barley Co, 11 Wall. 488: Goodyear v. Day, 2 Wall. Jr. 283: Orr v. Merrill, 1 Wood & 1\'1. 376; Nevins v. Johnson, 3 Blatchf. 80; Parsons v. Bedford, 3 Pet. 446: Fenn v. Holme, 21 How. 484; Cropley v. Beverly, Webs. Pat. Cas. 119: Hipp v. Babin, 19 How. 271; People v. Houghtaling, 7 Cal. 348: Colburn v. Simms, 2 Hare, 543: Smith v. London & S. R. Co. Kay, 415; Bailey v. Taylor, 1 Russ. & M. 75; Price's Co. v. Banwen's Co. 4 Kay & J. 727; Davenport v. Rylands, L. R.1 Eq. 302; Betts v. Gallais, L. R. 10 Eq. 392; De Vitre v. Betts, L. R. 6 H. L. 321; Garth v. Cotton, 1 Dick. 183. In illustration, as analogous: Parrott v. Palmer, 3 Mylne& K. 640; Jesus ColI. v. Bloom, 3 Atk. 262; Bish. of Winchester v. Knight, 1 P. Wms. 406: Powell v. Aiken, 4 Kay & J. 343; Higginbotham v. Hawkins, L. R. 7 Ch. Ap. 679; Martin v. Porter, 5 Mees. & W. 351; Morgan v. Powell, 3 Q. B. 278: Wood v. Morewood, Id. 440; Hilton v. Woods, L. R.4 Eq. 432; Jegon v. Vivian, L. R.6 Ch. Ap. 742.
Municipal Bonds-Coupons-Limitation of Aotion. TOWN OF KOSHKONONG V. BURTON. Case decided in the supreme court of the United States, October term, 1881.· In error to the circuit court for the western district of Wisconsin, the judgment of which court was reversed. Ha1'lan, J. The cause of action upon a coupon of a municipal bond issued under the statutes of Wisconsin, whether detached from the bond or not, accrues, and limitation commences at and from its maturity. The legislature may require, as to existing causes of action, that suits for their enforcement shall be barred unless brought within a less period than that prescribed when the contract was made, or the liability incurred, from which the iJause of action arose. The exertion of this power is, however, subject to the fundamental condition that a reasonable time, taking all the circumstances into consideration, be given by the new law before the bar takes effect. If interest upon interest, whether arising upon express or implied agreement, is allowed by the local law, at the time of the contract, that right cannot be impaired by a subsequent legislative declaration as to what was, in the jUdgment of that department, the true intent and meaning of the statutes prescribing and limiting the rate of interest in force when the contract was made. The utmost effect to be given to such legislative declaration is to regard it as an alteration of the existing law in its application to future transactions. The cases cited in the opinion were: Amy v. Dubuque, 98 U. S. 470, reaffirmed. As to the constitutional power of the legislature: Terry v. Anderson, 95 U. S. 633; Hawkins v. Barney, 5 Pet. 457; Jackson v. Lamphil'e, 3 Pet. 280; Sohn v. Waterson, 17 Wall. 596; Christmas v. Russell, 5 Wall. 290; Sturges v. Crownenshield, 4 Wheat. 122; Osborn v. Jaines, 17 Wis. 592: Parker v. Kane. 4 Wis. 1; Falkner v. Dorman, 7 Wis. 338. Allowance of interest: Mills v. Town of Jefferson, Wis. 56; Spencer v. MaXfield, 16 Wis. 185; Pruyn v. City of Milwaukee, 18 Wis. 386; Gelpcke v. Dubuque, 1 Wall. 175; Aurora v. West, 7 Wall. 105; Town of Genoa v. Woodruff, 92 U. S. 502: Walnut v. Wade, 103 U. S. 696. The law as the rule of decision: Salters v. Tobias, 3 Paige, 344; Ogden v. Blackledge, 2 Cranc!I, 276.
BOTES 011' DEOISIONS.
BID of Lading-Negotiability.
POLLARD 'V. VINTON. Supreme court of the United States, October term, .1.881, in error to the circuit court for the district of Kentucky, and affirming the judgment. Miller, J. A bill of lading is at once a receipt and a contract; it is an acknowledgment of the receipt of property on board the vessel, a contract to carry safely and deliver. The receipt of the goods lies at the foundation of the contract to carry and deliver, and if no goods are received there can be no valid contract to carry or to deliver. The person to whom such a bill of lading is first delivered cannot hold the signer responsible for goods not received by the carrier, as neither the master of the vessel . nor the shipping agent has authority to give a bill of lading for goods or cargo not received for shipment. Such a bill of lading. is void in the hands of a third person who may have afterwards· in good faith .taken it and advanced money on ,it. T. Ellery Anderson, for plaintiffs in errror. B. H. Bristow, for defendants in error. The cases cited in the opinion were: The Freeman ·· Bucktngham, 18 How. 182; Grant v. Norway, 10 Com. B. 665; Hubbersty v. Ward, 8 Exch. 330; Goleman v. Riches, 16 Com. B. 104; Walter v. Brewerj 11 Mass; 99. See, also, McLean v. Fleming, Law Rep. 2. H. L. 128. That a bill of lading is to be regarded in a double aspect, as a receipt and as a contract, see Good· rich v. Norris, Abb. Adm. 196; The Delaware, 14 Wall. 601; Blaikie v. Stembridge, 6 Com. B. (N,' S.) 894; Bates v. Todd, 1 Moody & R. 106; Berkley v. Wattling, 7 Adol. & E. 29; Wayland v. Mosely, 5 Ala. 430; Brown v. Byrne, 3 Ellis & B. 702; but compare Knox v. The Ninetta, Crabbe, 534. As a receipt, its statements are prima lame evidence only, and may be explained by parol evidence. Desty, Ship. & Adm. § 220, citing many cases.
THE UNION PAPER BAG MACH. Co. 11. NUON, (two cases.) NIXON 11. THEU. P. B. M. Co., (two cases.) These cases were appeals from the circuit court for the southern district of Ohio, and were decided March 6, 1882, in the supreme court of the United States. Mr. Chief Justice Waite delivered the opinion of the court. The right of an owner of a patented machine, without any conditions attached to his ownership, to continue the use ot his machine' during an extended term of the patent, is well settled; and his power to sell the machine and transfer the accompanying right of use is an incident of unrestricted ownership. Licensees of a patent cannot sue for an infringement. All their rights must be enforced through or in the name of the patentee, and where the license ceases when the term expired, it follows that during the extended term, no questions can arise under the license. The licensees take their title subject to the rights of the unrestricted owner. A decree will not be reviewed on appeal for the mere purpose of settling the costs. Goo. Harding, for Union Paper Bag Mach. Co. E. W. Kittredge and Jas. Moore, for Nixon et al. The cases cited in the opinion were: Rloomer v. McQuewan, 14 trow. 539; Chaffee v. Boston Belting Co. 22 How. 223; Mitchell v. Hawley, 16 Wall.