alized. He instructed his lawyer to make the best settlement of the matter that he could, and a settlement was soon effected by which the whole of Mr. Smith's parcel of land in the burnt district was conveyed to Mr. Ingalls, who gave back to Mr. Smith a mortgage for the whole amount which the latter had expended in the erection of his building, together with what he had paid for the parcel added by him to the original lot. Mr. Smith, not liking to have anything to remind him of his one unfortunate speculation, soon sold and assigned his mortgage to the Massachusetts Hospital Life Insurance Company; and as the well-known counsel of that institution has now examined and passed the title, we may presume that there are in it no more flaws remaining to be discovered.

In conclusion, we may say that Mr. William Ingalls, after having been for some ten years a reviler of the law, especially of that portion of it which relates to the title to real estate, is now inclined to look more complacently upon

it, being again in undisturbed and undisputed possession of his old estate, now worth much more than before, and in the receipt there from of an ample income which will enable him to pass the remainder of his days in comfort, if not in luxury. But, though Mr. Ingalls is content with the final result of the history of his title, those lawyers who are known as "conveyancers" are by no means happy when they contemplate that history, for it has tended to impress upon them how full of pitfalls is the ground upon which they are accustomed to tread, and how extensive is the knowledge and how great the care required of all who travel over it; and they now look more disgusted than ever, when, as so often happens, they are requested to "just step over" to the Registry and "look down" a title; and are informed that the title is a very simple one, and will only take a few minutes; and that So-and-so, "a very careful man," did it in less than half an hour last year, and found it all right, and that his charge was five dollars.

THE

HE history of the Night Law School of the University of Minnesota is peculiarly interesting, as well as instructive with reference to the development of legal education in this. country. The University of Minnesota Law School was first established in 1888, at a time when there was already in the cities of St. Paul and Minneapolis

a large urban population at the very door of the University. From the beginning it was apparent to the administration of the University that there were many capable young men in the Twin Cities who desired to study law, but whose circumstances compelled them to work during the day in order to gain a livelihood. For the benefit of these

young men, night classes were held during the first session of the Law School. The records do not make any distinction between the day students and the night students until the session of 189192, when we find that 64 of the 229 undergraduates were in attendance upon the night classes.

During the first four years of the history of the school no distinction no distinction whatever was made between the day students and the night students in regard to the time required for winning a degree; both classes of students being required to spend two years in the Law School. In September, 1892, the University administration became convinced that the night students could not accomplish as much work in two years as could the day students. They therefore increased the length of the night course to three years. In September, 1895, the day course was also increased to three years. From that date until 1907 the policy of counting a year's work by the night students as equivalent in all respects to a year's work by the day students was pursued. The result was necessarily very greatly to increase the number of students taking their work at night, as compared with the numbers in the day school.

A careful examination of the curricula during these years shows that the whole course required for the degree in the day school was composed of about 900 lecture hours, while that required of the night students embraced no more than 600. This smaller amount of classroom attendance required of the night students, together with the possibility of spending the day in gainful employments, placed a heavy premium upon the night courses, especially in the case of the more mature, earnest, and ambitious students. It seems that

a very large percentage of this latter class elected to go into the night school, with the result that, on account of the greater maturity and seriousness of its membership, the night school appears to have done more efficient work than the day school. The result of the operation of these influences can be seen in the fact that the night classes steadily gained in numbers over the day classes, until in one year, 1896-97, there were 239 night students as compared with 195 day students.

In 1907, in accordance with the resolution of the Association of American Law Schools, the night course was extended to four years. The result was to diminish the attendance upon the night school by one-half. In the summer of 1911 a careful examination was made into the condition of the Law School and a report made to the Board of Regents, showing that the course as then given for the LL. B. degree covered during the three years of the day school about 1,000 lecture hours, while in the four years of the night course there were about 700 lecture hours.

It was then decided by the faculty, with the approval of the Regents, that the course of instruction in the day school should be extended so as to be equal to what may be called the standard three-year course in the best American Law Schools, namely, about 1,200 lecture hours. It then became apparent that, if the night course were to be kept upon an equality in thoroughness and extent with the day course, it would need to be extended so as to cover a similar number of hours. was felt that a night course leading to the same degree as given in the day course must either be so extended as to cover the same amount of work or be abandoned. It quickly became apparent

It

that a night course embracing 1,200 hours would extend over not fewer than six years. Such a long period was believed to be wholly impracticable. Therefore it was decided to abandon the night course in so far as it led to a degree.

The history of the Night Law School of the University of Minnesota disclosed a very real demand for instruction in law in evening classes, and it was at once agreed that this demand should be met by the State University. To accomplish this result without endangering the thoroughness and extent of the regular work of the Law School done in its day classes, the following plan was worked out; the faculty having in mind the demonstrated fact that quite a large percentage of the night students. studied law as an aid to their business careers, rather than because they intended to enter upon the practice of the profession :

Under the general scheme of University extension work carried on by all departments of the University, the Law School offered evening courses in the Law Building covering all of the branches of substantive law customarily taught in Law Schools. These courses, of the same general nature as the corresponding courses in the Law School curriculum, were planned to be rather less extensive and to cover a period of three years, being substantially the same as the night courses formerly given. Examinations are regularly held in these extension courses, and the student who completes three years of work will be given a certificate to that effect.

Under this plan, the occasional night student, who desires to qualify himself for admission to the bar, can after completing his three years of night work, take the procedural courses in the day school during a fourth year, and then go to the bar by passing the examination set by the State Board of Bar Examiners.

The plan for the conduct of night work further provided a means whereby the exceptionally able student, who is not infrequently found in night classes, may secure University credit and ultimately win his degree. Any student passing an examination in a night course in any subject with the grade of "Good" will be admitted to the regular Law School examination in that subject. If he passes this regular examination, he will be given credit for the subject in the regular Law School course. If he succeeds in thus securing credit for all of the required Law School work, he will be graduated with the regular class in the year in which he completes his work.

It is believed that by this plan the quality and extent of the regular Law School course leading to the degree are amply safeguarded, and at the same time an adequate opportunity for securing legal training is afforded to the young man who is compelled to gain a livelihood by working during the day, whether he desires such legal training merely as as commercial training, whether he seeks thus an approach to the bar, and even provides a method of securing a law degree in spite of the handicap under which he labors.

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