Education.-The Department of notwithstanding the severe losses of Education lost a number of teachers the epidemic. by their entry into military service Commerce and Industries.-The exand because of low salaries. Its work ternal trade in the fiscal year 1919 was seriously interrupted by the reached a total of $141,869,400, being earthquake and the influenza epidem- $4,223,096 in excess of the recordic. Notwithstanding these handicaps, breaking figures of the preceding year. the work accomplished was creditable, The trade balance in favor of Porto and the total enrollment increased 18,- Rico was $17,095,680. Exports in000 over the preceding year, being creased about five and one-half million 160,794; in addition, 5,722 attended dollars over those of the preceding private schools. The number of teach year, about half a million dollars be ers employed was 2,984, of whom all ing due to the increase in the price of but 148 were native Porto Ricans. coffee, though the crop itself was the Twenty new school buildings were smallest since 1905. There was an incompleted during the year, 24 more crease in sugar shipments. some of are under construction, and 26 new which, however, represented part of school sites were acquired. The num- the 1918 crop which was held over ber of buildings used for schools was awaiting shipment. Sugar remains 1,724, 529 of which were public property and 1,195 were rented. The total expenditure for school work was $2,467,703.29. Although statistics show substantial progress, only a beginning has been made in the task of educating the people. The situation is thus described by the Governor in his annual report for 1919:

Much has been already accomplished, wide popular interest has been created in the education of the children, and an

excellent foundation has been laid upon which to build an

adequate modern school system for all the children of the Island. The need now is for larger funds for every phase of educationa! work.

the chief export, though its percentage of the total value of exports has dropped from 69 per cent. in 1916 to a little more than 60 per cent. in 1919. The production of 1919 was 47,795 tons less than the crop of 1918. There were notable increases in the exportations of coconuts and honey. Other articles of export decreased about a million and a half dollars, due to the lack of transportation facilities for fruit shipments and to the decline in the value of cigar and tobacco shipments.

Imports decreased nearly a million dollars, principally in the items of cotton goods, iron and steel manufactures, fertilizers, leather goods, and meats, and of beans and peas, due to home production. Increases were noted in importations of rice and wheat flour, fish, and dairy products.

The total exports for the last three fiscal years are shown in the following table:

The last Legislature rose to the occasion
and increased appropriations so that next
year the expenditures from all local
sources will reach about $3,000,000.
If
Congress would supplement the local ef-
fort by a generous appropriation of Fed-
eral funds, rapid progress could be made.
Sanitation. The regular work of
the Department of Health was also
greatly interrupted by efforts to con-
trol the influenza. Of the total num-
ber of deaths in the fiscal year end-
ing June 30, 1919, 39,974, those due
to the epidemic were 10,888, which in-
creased the death rate from 27.71 per
thousand in 1918 to 31.75. Seventy- Tobacco
two per cent. of the total deaths was
due to tuberculosis, malaria, hook-
worm, and infant mortality. The tu-
berculosis sanitarium is nearing com-
pletion, and other hospitals are being
constructed. The figures for infant
mortality, though slightly below those
for the two preceding years, are dis-
tressingly high. Much attention is
being devoted to this subject. The ex-
cess of births over deaths was 13,374,

Coffee

Sugar

Fruits
All other

11,723,712

3,628,214

2,898,580

7,210,790

$74,294,022 $79,496,040

Total

$54,015,903

American goods comprised 93 per cent. of total purchases, and 89 per cent. of all shipments were to the United States, as compared with 89 per cent. and 80 per cent., respectively, in 1914, the last year before the war.

VIRGIN ISLANDS

lowed by American laws, customs, and ideals as soon as possible. These people are pleading to be Americanized. There great possibilities in these islands.

are

They should no longer be neglected.

General Conditions. A change of administration took place in the Virgin Islands on April 8, 1919, when Rear-Adm. James H. Oliver, U. S. N., The most important agriculture in was relieved by Rear-Adm. Joseph W. the islands is sugar, of which approxOman, U. S. N., as governor. imately 10,000 tons was exported in The Governor's report shows that the fiscal year. During the year the many minor improvements were made Government succeeded in opening the during the fiscal year ending June Porto Rican market to cattle from the 30, 1919, but that no active work Virgin Islands. About $30,000 worth along the lines of expansion has been of cattle were exported, and it is possible owing to lack of funds. thought that the cattle-raising inPressing problems are an increase of dustry will eventually become an imeducational facilities, maintenance of portant one. Exportation of cattle to efficient police protection, improve- Porto Rico was formerly prohibited ments in the medical service and sani- on the ground that the Virgin Islands tation service, the dredging of St. were in the tick-infested area. Thomas Harbor, and the establishEducation. Some improvement is ment of public libraries and of a noted in the public schools during the poor farm to care for the paupers. fiscal year 1919, although the departDuring the wa many additional cases ment was greatly handicapped by the of poverty were added to the already lack of funds. During the year two large number of poor, and it is esti-assistant directors of education were mated that fully 2,500 persons, 10 per appointed, two new school buildings cent. of the population, may be classed and a supply of maps, books, etc.,

as paupers.

The Governor reports that the amount annually appropriated by Congress has not permitted of much improvement over the old order of things, and there is urgent need for additional funds if the Government is manner approaching

to be run in a American standards.

were acquired, and a plan was perfected whereby a teacher's training class, composed of natives, has been organized. The most urgent needs are high schools and reform or training schools. There are over 3,000 school children, which represent about one-eighth of the population. He states also Health and Sanitation.-Perhaps that there is growing unrest among the most important work accomthe inhabitants at the failure to plished since the transfer of the ischange the old Danish laws, continued lands to the United States has been in force by Congress under the act of in the department of health. In St. March 3, 1917, and that work is pro- Thomas the death rate has decreased gressing on the drafting of a modern from 39.4 to 23.9 per 1,000. Similar American code. As to this he says: favorable conditions exist in the mu"The inhabitants as a whole welcomed nicipality of St. Croix. Marked atthe change of sovereignty in the belief tention has been paid to infant-weland hope that conditions would be im fare work, and the infant mortality proaching when unrest and dissatis-duction from 248 in 1917 to 149 in proved, but the time is rapidly ap- per 1,000 births shows a striking refaction will prevail unless something| more tangible is done." As evidence tention during the year, and much of this unrest he refers to the testi-stress was laid on mosquito eradica

mony before a committee of Congress |

in August, 1919.

1918.

Food inspection received at

tion. A successful undertaking has The report of this been the conducting of a training school for native nurses at each muThe Americans, since their occupation, year the American Red Cross comnicipal hospital. During the fiscal

committee contained the following:

have done considerable work along lines

as

people of the islands feel that they have gical instruments, and laboratory ap

to education. The pitals with up-to-date furniture, sur

been neglected by the United States; that

when the American flag went up in the

Virgin Islands, it should have been fol-sity for increased hospital facilities.

pliances. There is an urgent neces

VIII. LAW AND JURISPRUDENCE

FRANCIS M. BURDICK

FOREIGN JURISPRUDENCE

Legislation. The volume of peace the intention could be established by legislation during the year in Great orders-in-council dealing with the Britain is meager. Ch. 52 (8 and 9 lands. The opinion contains an inGeorge V) prohibits all persons teresting discussion of the rights of from searching or boring for or get- aboriginal tribes in lands which they ting petroleum within the United inhabit, and reaches the conclusion Kingdom unless acting on behalf of that in this particular instance the the Government or holding a license rights of the aborigines were at the under the Act. Exceptions are made disposal of the Crown after the flight in favor of those who were using any of their king and the conquest of supply of natural gas for commercial their lands. purposes when the Act was passed and of those who in the course of mining or other lawful operations might set petroleum free. By Ch. 59 power to determine the date of the termination of the Great War is given to His Majesty in Council, the only limitation being that "the date so declared shall be as nearly as may be the date of exchange or deposit of ratifications of the treaty or treaties of peace." This limitation is minimized by the annexed provision that "the date declared shall be conclusive for all purposes of this Act." Chapter 3 (9 George V) confers upon a Secretary of State power to regulate air navigation over the British Islands and the territorial waters adjacent thereto and adds various provisions to the Aerial Navigation Act of 1911 and 1913.

Contracts. The defendant agreed to construct a steamer for plaintiff, subject to a proviso that if France became engaged in an European war by reason of which defendant could not within 18 months from the agreed date of completion deliver the steamer, the contract should be void, and all the money paid by the purchasers should be repaid to them. It was held that the Great War prevented defendant (a French company) from delivering the steamer and discharged it from all contract obligations. (New Zealand Shipping Co. v. Société des Ateliers et Chantiers de France, 1919 A. C. 1.)

A contract for the sale and delivery of goods "as requested" does not hind the seller for an indefinite period, but only for a reasonable time. Hence a buyer to whom goods were delivered Judicial Decisions: Privy Council as requested during a reasonable peDecisions. The high political impor- riod cannot after the lapse of three tance of topics which fall to the years compel the seller to deliver the Privy Council for examination is il-balance of the goods named in the lustrated by the case In re Southern Rhodesia (1919 A. C. 211, 88 L. J. P. C. 1). The conquest of a part of S. Rhodesia by the British South African Co. gave to the Company no political dominion over the territory but constituted it a sort of trustee or mandatary for its administration. It was not essential that the Crown should issue a formal proclamation of its intention to annex this region;

contract. The seller is entitled to treat the contract as having been cancelled by the buyer. (Pearl Mill Co., Ltd., v. Ivy Tannery Co., Ltd.,-K. B.-.)

Parties had entered into an oral contract for the sale and purchase of a house. The vendor gave to the vendee a receipt for the deposit made by the latter, containing also a statement of the purchase price, of the