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Response or Comment

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A case just decided in the Supreme Court of the United States, coming to that court from the Canal Zone, shows the great difficulties under which our courts labor when they are called on to interpret and administer the law in our extra-continental possessions. The courts have apparently had the most difficulty in amalgamating the Roman law and the common law in cases involving questions of delictual liability. In the case of Fernandez v. Perez (1906), 202 U. S. 80, the procedural question was presented as to the validity of an action on the case for the wrongful levy of an attachment brought in the United States District Court for the District of Porto Rico. A decision of the point involved a discussion of the relation of torts to crimes in the Spanish law. Such a discussion was presented in 6 MICH. L. Rv. 136, 149, (107).