contracts. When his customers are driven away, and the good will of his business is destroyed, it will be too late, so far as he is concerned, for the punishment of the appellees by the criminal law to reestablish his ruined business, or even prevent future loss. If the circuit court had granted the injunction, and the defendants had disobeyed it, and he had punished them for contempt, the punishment would have been for their disobedience of the order of the court, regardless of whether their acts were also a violation of the criminal law of the land for which they might be indicted and punished in the criminal court. His judg ment punishing them for contempt would have been no bar to the criminal proceeding against them for their violation of the law, and would not have affected this proceeding in any way. His judgment would have established nothing more than that they were guilty of contempt of court in disobeying his orders. Whether they were also guilty of a criminal offense would have to be tried in the proper forum, and not in this action. The power of a court to punish for contempt is as old as the common law, and inherent in every court. The punishment for contempt would relate only to acts done after the injunction was granted, in disobedience of it; and even in this proceeding the defendants are protected as to a jury trial by section 1291, Ky. St., 1903, which provides: "A court shall not for contempt impose upon the offender a fine exceeding thirty dollars ($30), or imprison him exceeding thirty hours, without the intervention of a jury."

It is also urged that the plaintiff had an adequate remedy under the criminal code by having the defendants to give security to keep the peace and be of good behavior. The rule that an injunction will not be granted where there is an adequate remedy at law refers to legal remedies, and not to criminal proceedings. In no case has it ever been otherwise applied, so far as we can find. It looks to the prevention of offenses, and not to the redress of private wrongs. It is begun by a warrant issued in the name of the Commonwealth, and is a prosecution by the Commonwealth, under the control of its officers. bond is required, it is taken to the Commonwealth. When the plaintiff's property is about to be destroyed, he is entitled to a remedy in his own name, and which he can himself control to protect him in the enjoyment of his own. The fact that the Commonwealth might also take out a proceeding to require the defendant to give security for good behavior is immaterial, for both proceedings may be prosecuted at the same time-one in the criminal court by the Commonwealth, and the other in equity by the plaintiff; one to prevent the commission of offenses, the other to preserve the plaintiff's property from destruction.

LABOR ORGANIZATIONS BENEFIT FUNDS-RULES-Steinert v. United Brotherhood of Carpenters and Joiners of America, Supreme Court of Minnesota, 97 Northwestern Reporter, page 668.—In this case Augusta Steinert, as administratrix of the estate of Ferdinand Steinert, deceased, sued the United Brotherhood of Carpenters and Joiners of America for a payment alleged to be due the said Steinert's estate from the benefit fund of the brotherhood above named. There was no question as to the facts in the case. Mr. Steinert had been a mem

ber of the organization in good standing for a number of years prior to his death and was at that time a member unless he had ceased to be so because he had engaged in the sale of liquors a short time before. The constitution provided that "No person who engages in the sale of intoxicating drinks can be admitted or retained as a member." Another provision was to the effect that: "Each member will be entitled to all the benefits, rights, and privileges of this United Brotherhood, as prescribed in this constitution, by strictly adhering to his obligation, and by him and his local union obeying the constitution and rules." The municipal court of Minneapolis had allowed the claim against the brotherhood, whereupon an appeal was taken to the supreme court, which affirmed the judgment of the court below. The question involved and the grounds on which the award was made are set forth in the remarks of Judge Collins, who delivered the opinion of the court, from which the following is quoted:

The question is: Must charges be preferred, and an opportunity to defend given, to an accused member before his membership ceases, or does the act of selling intoxicating drinks terminate the membership without any further proceedings? That Steinert disregarded the laws of the order stands admitted, but it does not follow that this fact of itself ended all liability of the defendant on his certificate of membership, issued when he was eligible, under which he had good standing, and in which he had acquired a property right. This depends entirely on the contract of membership, of which the constitution was a part. It was expressly provided in the certificate that a member must strictly adhere to his obligation, and obey the constitution and all rules of the union based thereon. No person who engages in the sale of intoxicating drinks can be "retained" as a member. Provisions of this kind, which may deprive one of property rights acquired when paying dues from time to time, are to be construed strictly, for forfeitures are not favored in the law. A member should not be deprived of benefits arising out of his certificate of membership, unless a construction of the constitution makes such a result absolutely necessary. We do not regard these constitutional provisions, taken as a whole, as indicating an intent to make the one above quoted self-executing or operative. It would have been very easy for the association, which undoubtedly prepared its own constitution, if such had been the intent, to have provided explicitly that in case a member engaged in the sale of intoxicating drinks his membership should forthwith and immediately cease, his certificate should stand canceled, and that he should have no further rights under it. No such language, or its equivalent, was used. By the use of the words "retain" in one place and "retained" in another, the provisions were made ambiguous and indefinite. The difficulty in construing is increased by the provisions which seem to be applicable respecting the preferring of charges and the methods prescribed for trials of offending members. One who has properly united with a beneficial association, and has paid his assessments in due season, can not be declared to have forfeited his rights upon doubtfully constructed provisions in the constitution; and the one in question was not selfexecuting or operating.

LAWS OF VARIOUS STATES RELATING TO LABOR ENACTED SINCE JANUARY 1, 1896.

[The Second Special Report of this Bureau contains all laws of the various States and Territories and of the United States relating to labor in force January 1, 1896. Later enactment are reproduced in successive issues of the Bulletin from time to time as published.]

ILLINOIS.

ACTS OF 1903.

PAGE 187.-Employment of children.

SECTION 1. No child under the age of fourteen years shall be employed, permitted or suffered to work at any gainful occupation in any theater, concert hall or place of amusement where intoxicating liquors are sold, or in any mercantile institution, store, office, hotel, laundry, manufacturing establishment, bowling alley, passenger or freight elevator, factory or workshop, or as a messenger or driver therefor, within this State. No child under fourteen years of age shall be employed at any work performed for wages or other compensation, to whomsoever payable, during any portion of any month when the public schools of the town, township, village or city in which he or she resides are in session, nor be employed at any work before the hour of seven o'clock in the morning or after the hour of six o'clock in the evening: Provided, That no child shall be allowed to work more than eight hours in any one day. SEC. 2. It shall be the duty of every person, firm or corporation, agent or manager of any firm or corporation employing minors over fourteen years and under sixteen years of age in any mercantile institution, store, office, hotel, laundry, manufacturing establishment, bowling alley, theater, concert hall or place of amusement, passenger or freight elevator, factory or workshop, or as messenger or driver therefor, within this State, to keep a register in said mercantile institution, store, office, hotel, laundry, manufacturing establishment, bowling alley, theater, concert hall or place of amusement, factory or workshop in which said minors shall be employed or permitted or suffered to work, in which register shall be recorded the name, age and place of residence of every child employed or suffered or permitted to work therein, or as messenger or driver therefor, over the age of fourteen and under the age of sixteen years; and it shall be unlawful for any person, firm or corporation, agent or manager, of any firm or corporation to hire or employ, or to permit or suffer to work in any mercantile institution, store, office, hotel, laundry, manufacturing establishment, bowling alley, theater, concert hall or place of amusement, passenger or freight elevator, factory or workshop, or as messenger or driver therefor, any child under the age of sixteen years and over fourteen years of age, unless there is first produced and placed on file in such mercantile institution, store, office, hotel, laundry, manufacturing establishment, bowling alley, factory or workshop, theater, concert hall or place of amusement, an age and school certificate approved as hereinafter provided.

SEC. 3. Every person, firm or corporation, agent or manager of a corporation employing or permitting or suffering to work five or more children under the age of sixteen years and over the age of fourteen in any mercantile institution, store, office, laundry, hotel, manufacturing establishment, factory or workshop, shall post and keep posted in a conspicuous place in every room in which such help is employed, or permitted or suffered to work, a list containing the name, age and place of residence of every person under the age of sixteen years employed, permitted or suffered to work in such room.

SEC. 4. No child under sixteen years of age and over fourteen years of age shall be employed in any mercantile institution, store, office, hotel, laundry, manufacturing

establishment, bowling alley, theater, concert hall, or place of amusement, passenger or freight elevator, factory or workshop, or as messenger or driver therefor, unless there is first produced and placed on file in such mercantile institution, store, office, hotel, laundry, manufacturing establishment, bowling alley, theater, concert hall or place of amusement, factory or workshop, and accessible to the State factory inspector, assistant factory inspector or deputy factory inspector, an age and school certificate as hereinafter prescribed; and unless there is kept on file and produced on demand of said inspectors of factories a complete and correct list of all the minors under the age of sixteen years so employed who can not read at sight and write legibly simple sentences, unless such child is attending night school as hereinafter provided.

SEC. 5. An age and school certificate shall be approved only by the superintendent of schools or by a person authorized by him in writing; or where there is no superintendent of schools by a person authorized by the school board: Provided, That the superintendent or principal of a parochial school shall have the right to approve an age and school certificate, and shall have the same rights and powers as the superintendent of public schools to administer the oaths herein provided for children attending parochial schools: Provided, further, That no member of a school board or other person authorized as aforesaid shall have authority to approve such certificates for any child then in or about to enter his own establishment, or the employment of a firm or corporation of which he is a member, officer or employee. The person approving these certificates shall have authority to administer the oath provided herein, but no fee shall be charged therefor. It shall be the duty of the school board or local school authorities to designate a place (connected with their office, when practicable) where certificates shall be issued and recorded, and to establish and maintain the necessary records and clerical service for carrying out the provisions of this act.

SEC. 6. An age and school certificate shall not be approved unless satisfactory evidence is furnished by the last school census, the certificate of birth or baptism of such child, the register of birth of such child with a town or city clerk, or by the records of the public or parochial schools, that such child is of the age stated in the certificate: Provided, That in cases arising wherein the above proof is not obtainable, the parent or guardian of the child shall make oath before the juvenile or county court as to the age of such child, and the court may issue to said child an age certificate as sworn to. SEC. 7. The age and school certificate of a child under sixteen years of age shall not be approved and signed until he presents to the person authorized to approve and sign the same, a school attendance certificate, as hereinafter prescribed, duly filled out and signed. A duplicate of such age and school certificate shall be filled out and shall be forwarded to the State factory inspector's office. Any explanatory matter may be printed with such certificate in the discretion of the school board or superintendent of schools. The employment and the age and school certificates shall be separately printed and shall be filled out, signed, and held or surrendered as indicated in the following forms.

SCHOOL CERTIFICATE.

(Name of school).

(City or town and date). This certifies (name of minor) of the ―th grade, can read and write legibly simple sentences. This also certifies that according to the records of this school, and in my belief, the said (name of minor) was born at (name of city or town) in (name of county) on the (date) and is now (number of years and months) old. (Name of parent or guardian),

(Residence).

(Signature of teacher) (Name of principal). Correct.

grade.

(Name of school).

EVENING SCHOOL ATTENDANCE CERTIFICATE.

(Date).

This certifies that (name of minor) is registered in and regularly attends the evening school. This also certifies that according to the records of my school and in my belief the said (name of minor) was born at (name of city or town) on the ― day of (year), and is now (number of years and months) old.

(Name of parent or guardian),
(Residence).

(Signature of teacher).
(Signature of principal).

AGE AND SCHOOL CERTIFICATE.

This certifies that I am (father, mother, guardian or custodian) of (name of minor), and that (he or she) was born at (name of town or city) in the (name of county, if known) and State or county of —, on the (day of birth and year of birth) and is now (number of years and months) old.

(Signature of parent, guardian or custodian),
(City or town and date).

There personally appeared before me the above named (name of person signing and made oath that the foregoing certificate by (him or her) signed is true to the best of (his or her) knowledge. I hereby approve the foregoing certificate of (name of child), height (feet and inches), weight complexion (fair or dark), hair (color), having no sufficient reason to doubt that (he or she) is of the age therein certified.

OWNER OF CERTIFICATE.

This certificate belongs to (name of child in whose behalf it is drawn) and is to be surrendered to (him or her) whenever (he or she) leaves the service of the corporation or employer holding the same; but if not claimed by said child within thirty days from such time it shall be returned to the superintendent of schools, or where there is no superintendent of schools, to the school board. (Signature of person authorized to approve and sign, with official character authority) (town, or city and date.)

In the case of a child who can not read at sight and write legibly simple sentences, the certificate shall continue as follows, after the word sentences: "I hereby certify that (he or she) is regularly attending the (name of public or parochial evening school)." This certificate shall continue in force just as long as the regular attendance of said child at said evening school is certified weekly by the teacher and principal of said school.

In any city or town in which there is no public or parochial evening school, an age and school certificate shall not be approved for a child under the age of sixteen years who can not read at sight and write legibly simple sentences. When the public or parochial evening schools are not in session, an age and school certificate shall not be approved for any child who can not read at sight and write legibly simple sentences. The certificate of the principal of a public or parochial school shall be prima facie evidence as to the literacy or illiteracy of the child.

SEC. 8. No person shall employ any minor over fourteen years of age and under sixteen years, and no parent, guardian or custodian shall permit to be employed any such minor under his control, who can not read at sight and write legibly simple sentences, while a public evening school is maintained in the town or city in which such minor resides, unless such minor is a regular attendant at such evening school. SEC. 9. The State inspector of factories, his assistants or deputies, shall visit all mercantile institutions, stores, offices, laundries, manufacturing establishments, bowling alleys, theaters, concert halls or places of amusement, factories or workshops, and all other places where minors are or may be employed in this State, and ascertain whether any minors are employed contrary to the provisions of this act. Inspectors of factories may require that age and school certificates, and all lists of minors employed in such factories, workshops, mercantile institutions and all other places where minors are employed as provided for in this act, shall be produced for their inspection on demand: And, provided further, That upon written complaint to the school board or local school authorities of any city, town, district or municipality, that any minor (whose name shall be given in such complaint) is employed in any mercantile institution, store, office, laundry, manufacturing establishment, bowling alley, theater, concert hall or place of amusement, passenger or freight elevator, factory or workshop, or as messenger or driver therefor, contrary to the provisions of this act, it shall be the duty of such school board or local school authority to report the same to the State inspector of factories.

SEC. 10. No person under the age of sixteen years shall be employed or suffered or permitted to work at any gainful occupation more than forty-eight hours in any one week, nor more than eight hours in any one day; or before the hours of seven o'clock in the morning or after the hour of seven o'clock in the evening. Every employer shall post in a conspicuous place in every room where such minors are employed, a printed notice stating the hours required of them each day of the week, the hours of commencing and stopping work, and the hours when the time or times allowed for dinner or for other meals begins and ends. The printed form of such notice shall be

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