52 HARVARD LAW REVIEW.

In Quincy's history of Harvard University, published in 1840, it is stated that the Law Library contains about 6,100 volumes. This shows a very rapid growth from 1833, — doubling in seven years. It is further stated to contain most of the valuable works in English and American Law, and in the Civil Law, together with a variety of others by writers of France, Spain, and Germany. At the end of 1858, the number of vol- umes is set down as 8,030, exclusive of text-books to be loaned to students. During the year 1857-58, 150 volumes were lost, and 11 1 vol- umes were added to the library. In 1870, the collection had increased to 12.800, the number added during 1869-70 being 198. It thus appears that the library nearly doubled in size from 1833 to 1840, and that in 1870 it was only a little more than twice as great as it was in 1840. It had a very rapid growth in the first period, and a much slower in the second. This was, doubtless, partly due to the fact that the earlier time was dur- ing the establishment of the library as a collection, but more to the pros- perity of the school. In these earlier years the number of volumes received as gifts was also much larger than in the last-named period. Harvard Law School Association. — The annual report of the treasurer of the Harvard Law School Association shows a gratifying increase in the number of members, — the decrease of last year being overbalanced, and a net increase made of twenty-three since 1892. During the last year, the association has appropriated out of its income enough to send the copy of the Review containing Professor Langdell's portrait to every member, and to establish and maintain for the current year the valuable course upon Conflict of Laws given by Professor Beale. It has been in many other ways, as always, a power for the good of the School. Mr. Justice Holmes's Article. — Anyone who has tried to follow the cases in which employers have sued the members of trades unions for interference with that pursuit of business which, they claim, ought to be unhampered, and the other litigation arising out of the same general question, must have been perplexed and exhausted, both by the contra- riety of the decisions and the variety and inconsistency of the reasons assigned. The courts, in apparent unconsciousness, have taken steps lead- ing — no man can see precisely whither. Mr. Wigmore, some years ago (21 Am. L. Rev. 509, 764), tried to explain all the cases, except Walker v. Cronin, 107 Mass. 555, on grounds of intimidation and the like; but in view of the more recent decisions, so simple an explanation will no longer serve. From this standpoint, Mr. Justice Holmes's discussion of malice and intent, with which the Review makes an auspicious beginning of its eighth volume, possesses peculiar interest. Whatever view may be taken of the decisions, it is evidently of prime importance that the courts should proceed in this manner with a clearer understanding than that which they now manifest, for the contrariety of decisions, some of them backed up by reasoning not always pertinent or consistent, will natu- rally do as much toward fomenting the costly quarrels which they seek to decide, as treatment of the matter such as Mr. Justice Holmes's should do toward clarifying the discussion and removing the misunder- standing, which is the cause of nine-tenths of the trouble.