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THE GREEN BAG

tion and the party against whom the injunction is asked, upon a bill stating a case within its general equitable jurisdiction, the court has authority to decide whether an injunction should issue and the character of such injunction, and any error on its part in improperly issuing the injunction or in issuing an injunction broader than is justified by the bill, is merely ground for reversal on appeal or writ of error, and is not available to defeat contempt proceedings for a violation of the in- junction as issued.

On the merits it is declared that a labor union which ordered a strike and which through its officers and members engaged in picketing and intimidating and threatening non-union employees, assaulting some and frightening others, was prop- erly adjudged guilty of contempt in violating an injunction restraining it from interfering with the business of their former employers, and from in- timidating other employees from doing their work or accepting employment.

In support of the holding the court cites Dore- mus v. Hennessy, 176 Ill. 608, 52 N. E. 924. 54 N. E. 524; Beck v. Railway Teamsters' Protective Union, 118 Mich. 497, 77 N. W. 13; Vegelahn v. Guntner, 167 Mass. 92. 44 N. E. 1077. INJUNCTION. (Violation - Persons Liable.) U. S. C. C. N. D. Ill. In Employers' Teaming Company v. Teamsters' Joint Council, 141 Fed. 679, a person not a party to an injunction suit is held liable to punishment for contempt for viola- tion of the injunction. An order was issued in a suit of equity against a labor union for an in- junction restraining defendants, their agents or servants, and all other persons aiding, abetting, or acting in concert with them or having knowl- edge of the order, from interfering with or in any manner injuring, obstructing, or stopping the business of complainant, which was a teaming company.

The order was widely published, copies were posted in public places and placed on each side of all of complainant's wagons, which also bore large signs calling attention thereto. The wagons were also operated under armed guards. In proceedings for contempt for violation of the

order, it was shown that respondent who was not a party to the suit was one of the most active in a mob which attacked one of complainant's wagons so placarded and guarded. and that he incited others to violence and himself threw stones at the teamsters and guards, and assaulted one of 'the guards while the latter was in charge of the police. The court holds on these facts that respondent must be deemed to have had knowledge of the order, notwithstanding the fact that he filed a sworn general denial of all the allegations of the petition, and it is further held that he was guilty of contempt in aiding and abetting the defendants in the cause in violating the order of the court and willfully obstructing its process.

INSURANCE. (Forfeiture.) Ky. The right of a life insurance company to summarily enforce a forfeiture through the mediumship of an assignment of the policy as security for a loan is denied in Mutual Life Ins. Co. of Kentucky v. Twyman, 92 S. W. 335. The insured in a paid-up policy borrowed money from the company and assigned the policy as collateral by an assignment authorizing the company on the non-payment of the debt to cancel the policy. Under this contract the company is denied the right, on the failure of insured to pay the note, to enforce its interest in the policy as collateral, by summarily canceling it. It is held that the company must resort to equity to enforce its rights based on the surrender of the policy, determined in the manner provided by the statutes of Kentucky, and that on the court finding that such value exceeded the debt, the sum left over should be ordered to be paid to insured or used for the purchase of paid-up insurance as the insured might elect.

INSURANCE. (Liability.) Ohio. - A rather peculiar variety of contract is held not to constitute an insurance policy, in State v. Laylin, 76 N. E. 567. A corporation was chartered to defend physicians and surgeons against civil prosecution for malpractice, and in prosecution of its business issued and sold to members of the medical profession a contract whereby it agreed to defend the holder of the contract against any suit for malpractice that might be brought against him during the term specified in the contract, but did not assume or agree to assume or pay any judgment that might be rendered against the insured in the suit. Such a corporation, it is held, is not engaged in the business of insurance, nor is the contract an insurance contract. Irrespective of the question thus decided as to form of contract, it is declared that a corporation created for the purpose of engaging in and carrying on such a business is not entitled to receive from the Secretary of State a certificate authorizing it to transact its business. for the reason that the business is professional business, which the statutes of Ohio expressly prohibit corporations from carrying on.

INTOXICATING LIQUOR. (Medicinal preparations.) Ark. Not every universal panacea can be retailed with impunity in Arkansas. Stelle v State, 92 S. W. 530. There the court has sustained a conviction for selling intoxicating liquors with-