C C.A

503, 12 L. R. A. (N. S.) 1053, 12 Ann. Cas. 233, where the subject is thoroughly discussed and the cases collected by Sanborn, C. J., and in a note to the last citation. A federal court has no jurisdiction, under the 13th Amendment, of a charge of conspiracy made and carried out in a state to prevent its citizens of African descent because of their color and race from making or carrying out contracts and agreements of labor; Hodges v. U. S., 203 U. S. 1, 27 Sup. Ct. 6, 51 L. Ed. 65. On a bill alleging a malicious conspiracy to interfere with carrying th"e mails and with interstate commerce, an injunction may be granted to restrain the ordering or causing a strike of the carrier's employes; Wabash R. •vert act that results in damage to the plaintiff; Nalle v. Oyster, 230 U. S. 165, 33 Sup. Ct. 1043, 57 L. Ed.. Some writers consider that there is in this country a tendency to extend the doctrine of criminal conspiracy and utilize it for the indictment of persons suspected of crime of which there is difficulty in obtaining sufficient proof. This tendency is the subject of extended discussion in an article on "The Judge-Made Law of Conspiracy," by F. P. Blair, in 37 Am. L. Rev. 33, in which the author contends that there has been a departure from the common law upon this subject It contains a valuable enumeration and discussion of the early English cases on the subject of conspiracy. As to conspiracies in connection with labor and labor unions, see Boycott; Labor Union; Strike; Combination; Restraint of Trade.