may be seized and held for the payment of taxes. City Nat. Bank v. Mahan, 21 La. Ann. 752. The title, "An act relating to the assessment and revision of taxes," is sufficient to sustain a provision relating to the mode of appointing members of boards of assessment and revision. State v. Hammer, 42 N. J. L. 435. An act, the title of which recites that it is a law for regulating the mode of assessing and collecting taxes throughout the state, is not invalid as to a particular city, in that it fails to mention that city in the title. Stewart's Succession, 41 La. Ann. 128. The title, "An act in relation to assessments in townships," sufficiently indicates provisions relating to a stay of collection of money paid on void assessments and to the mode of levying assessments in townships. State v. North Plainfield, 43 N. J. L. 349. ernment . The title, "An act to levy and collect a tax for the support of the state govto prescribe what persons, profession and property are liable to taxation, prescribe the method of receiving and collecting said taxes and to provide penalties and forfeitures for non-payment of taxes," is sufficient to embrace the imposition of a tax on "futures" and a provision that such tax shall be paid in full at the time of commencing the business of operating in "futures" and requiring registration with the ordinary at the time of payment of the tax and making the failure to pay the tax, or to register, an offense. McGhee v. State (Ga. 1893), 17 S. E. Rep. 276. The title, "An act to enforce the collection of taxes levied in the county of L.," is sufficient to sustain a provision making it unlawful for the owners of land in that county, on which taxes were unpaid, to peel bark or cut timber on such land. Prentice v. Weston, 47 Hun (N. Y.) 121. The title, "An act for the more rigid collection of the revenue," will sustain a provision relating to assessment and to the collection of three separate and distinct revenues and increasing the jurisdiction of justices of the peace in respect to the collection of taxes. State v. Whitworth, 8 Lea (Tenn.) 594. The title, "An act in reference to the collection of taxes " in a certain county, comprehends a provision that tax deeds shall be conclusive evidence of title. Ensign v. Barse, 107 N. Y. 329. the title, "An act to provide revenue by taxation of corporations, associations and limited partnerships," was held to refer to taxation without restriction to corporate associations and limited partnerships, and it was held that a tax on loans held by individuals was within the title. The title," The payment of a county's bonded indebtedness," embraces provisions authorizing the appointment of commissioners of a sinking fund, the levy of taxes, and the collection of and penalties for failing to pay the same. Owenboro, etc., R. Co. v. Logan County (Ky. 1889), 11 S.W. Rep.76. The title, "An act to establish taxing districts, and to provide the means for local government for the same," is sufficient to sustain provisions giving municipal franchises to communities within such district, together with the necessary legislative, judicial and police powers, and providing for offenses against such municipalities by officers and others. Luehrman v. Shelby County Taxing Dist.,2 Lea (Tenn.) 425. The title, "An act to authorize the construction and maintenance of a courthouse in C. county," is sufficient to support provisions relating to the levying and collection of taxes for that purpose, and conferring the power to appoint commissioners to receive such tax and apply it to the purposes of the act. McArthur v. Nelson, 81 Ky. 67. The title, "An act to provide for 'a board of equalization,'" sufficiently indicates provisions for such a board in every county of the state. Stewart v. Collier (Ga. 1893), 17 S. E. Rep. 278. The title," An act, a supplement to an act, entitled 'an act to provide revenue by taxation,'" sustains a provision that the exemption of certain banks from taxation should be confined to "so much of the capital and profits of such bank as shall not be invested in real estate." National Bank v. Chester County, 14 Fed. Rep. 239. The title, "An act to provide for the closing of the entrance of the tunnel of the L. R. Co. . . . in A. street," sufficiently indicates a provision for an assessment to raise a fund with which to compensate the railroad company for its losses and expenses in that behalf. People v. Lawrence, 36 Barb. (N. Y.) 177; People v. Lawrence, 41 N. Y. 137. The title, "An act attaching certain territory to the county of W. to enable In Com. v. Martin, 107 Pa. St. 189, said town to take stock in a railroad," local taxation to pay part of the expense of building a bridge were not indicated by the title, "An act making appropriations for the expenses of government;"1 and that the title, "An act to provide more just and equitable laws for the assessment and collection of revenue for state and county purposes,' was not sufficient to sustain provisions relating to the collection of municipal taxes. For other miscellaneous cases of insufficient titles, see appended note.3 h. INTOXICATING LIQUORS.-Provisions prohibiting or regulating the sale of intoxicating liquors are frequently inserted in the comprehends provisions erecting the annexed territory into a taxing district. Henderson v. Jackson County, 2 McCrary (U.S.) 619. The title, "An act to enable the supervisors to raise money by tax," sufficiently indicates provisions for raising a fund with which to pay existing or future judgments, and directions for ascertaining that such judgments were really due. Sharp v. New York, 31 Barb. (N. Y.) 574. The title, "An act to make provision for the government of the county of New York," embraces a provision that the real estate of a certain hospital, except such buildings actually used for hospital purposes, shall be liable to taxation. People v. Com'rs of Taxes, 47 N. Y. 502. License Cases.-The title, “A further supplement to an act regulating boroughs and authorizing the corporate authorities to levy and collect a license tax on hacks," is sufficient to sustain provisions authorizing the enactment of ordinances fixing reasonable rates of license taxes on all hacks and other vehicles used in carrying persons or property for pay, and limiting the compensation within a borough. Washington v.McGeorge (Pa. 1892), 23 Atl. Rep.222. A provision requiring vendors of lager beer, manufactured by themselves, to take out licenses, is embraced by the title "An act to raise additional revenue to pay the debts of the state by increasing the rates of licenses of ordinary keepers and traders." Keller v. State, 11 Md. 525; 69 Am. Dec. 226. The object of a provision that peddlers of drugs and nostrums shall obtain a license, under penalty of a fine to be recovered by action of debt in the name of the people, is sufficiently indicated by the title, "An act to regulate the sale of medicine in the state of Illinois." People v. Blue Mountain Joe, 129 Ill. 370. A title expressing the subject-matter of an ordinance to be the licensing of vehicles, and the fixing of rates for the same, is not inconsistent with provisions for the imposition of the license, or regulation of vehicles driven in the night, and for fixing rates of charges for use of vehicles, and the licensing of drivers. St. Louis v. Green, 7 Mo. App. 472. The title, "An act to define the duties, powers, qualifications and liabilities of assessors." comprehends a provision referring disputes as to values to the board of equalization for decision. International, etc., R.Co.v.Smith County, 54 Tex. 10. The title, "An act to ratify and confirm certain proceedings of the board of trustees of the village of A.," sufficiently indicates a provision ratifying an invalid assessment. People v. Wil son, 3 N. Y. Supp. 326. The title, "An act providing for the improvement of the F. road at the cost of the property benefited thereby," sufficiently indicates a provision for assessment of the adjoining property within eight hundred feet of either side of the road. Graham v. Conger, 85 Ky. 582. See generally State v. Lasater, 9 Baxt. (Tenn.) 584; Com. v. Dickinson, 13 Phila. (Pa.) 585; Slymer v. State, 62 Md. 237; In re Broom's Estate (Pa. 1893), 25 Atl. Rep. 630; State v. Wright (45 La. Ann.), 12 So. Rep. 129; Allen v. Pioneer Press Co., 40 Minn. 117; 12 Am. St. Rep. 707. 1. Insufficient Titles Relative to Taxa tion.-People v. Chautauqua County, 43 N. Y. 10. 2. Knoxville v. Lewis, 12 Lea (Tenn.) 180. 3. The title, "An act to exempt from taxation public property used for public purposes and places of religious worship," does not embrace the proviso that "all property, real or personal, other than that which is in actual use legislative charters of municipal, eleemosynary, and private corporations, and have been held to be sufficiently indicated by titles expressing no other purpose than that of incorporation. Under a title expressing the purpose of the act to be to regulate the sale of liquor, provisions prohibiting the sale and imposing penalties may be embraced; 2 or provisions declaring the holder of a liquor license and his bondsmen liable for damages sustained from a sale; 3 or a provision imposing a license tax; or a provision declaring disorderly houses where liquor is sold to be nuisances.5 See note for miscellaneous instances of sufficient titles. On and occupation for the purposes aforesaid, and from which any income or revenue is derived, shall be subject to taxation." Sewickley v. Sholes, 118 Pa. St. 165. The title, "An act to allow further time for the treasurer of H. county to make returns of delinquent taxes," is inconsistent with a provision allowing a former treasurer additional time in which to make supplementary returns of delinquent taxes. Henrico County v. Magruder, 84 Va. 828. The title, "An act making appropriations for the expenses of state offices and state governments for the years 1885-6, and to provide a tax for paying the same," is not sufficient to embrace a section authorizing a tax to raise money with which to pay interest to counties on proceeds of sales of swamp lands theretofore accruing. Sanilac County v. Aplin, 68 Mich. 659. The title, "An act to amend an act providing for the registration of precinct bonds," will not support a provision for levying taxes to pay such bonds. Burlington, etc., R. Co. v. Saunders County, 9 Neb. 507. The title, "An act to fix the license tax of stevedores," is not consistent with a provision for the examination of persons as to their qualification for performing the duties of stevedore. State v. Palmes, 23 Fla. 620. The title, "An act to provide for assessment of unclaimed military lots and tracts of land in A. and G. counties, and for the collection of state and county taxes thereon, by selling the delinquent lands and turning the net proceeds into the treasury," does not embrace a provision that fees charged those counties for previous searches in land offices shall be remitted, or that their agent shall have free access to the records. Scharf v. Tasker, 73 Md. 378. The title, "An act to require assesto assess all seated lands sors in the county in which the mansion house is situated where the county lines divide a tract of land," does not indicate a provision relating merely to assessment of lands divided by township and borough lines. La Plume v. Gardner (Pa. 1892), 23 Atl. Rep. 899. See generally Com. v. Bender, 7 Pa. Co. Ct. Rep. 620; State v. McCann, 4 Lea (Tenn.) I. 1. Ex parte Moore, 62 Ala. 471; Gloversville v. Howell, 7 Hun (N. Y.) 345; Neifing v. Pontiac Tp., 56 Ill. 172; O'Leary v. Cook County, 28 Ill. 534. 2. Williams v. State, 48 Ind. 306. See also State v. Adamson, 14 Ind. 296; Thomasson v. State, 15 Ind. 449. 3. Poffenbarger v. Smith, 27 Neb. 788; Durein v. Pontious, 34 Kan. 353. The title "An act to regulate and license the sale of liquors," comprehends a provision that the applicant shall give bond to pay all fines and costs imposed for violation of the act as a condition precedent to the issuing of the license. Kane v. State, 78 Ind. 103. 4. State v. Dogherty (Idaho 1892), 29 Pac. Rep. 855. 5. O'Kane v. State, 60 Ind. 183; State v. Campbell (Kan. 1893), 32 Pac. Rep. 35. 6. Sufficient Titles of Liquor Acts.The title, "To provide for the collection of special taxes on dealers in spirituous or malt and intoxicating bitters, and for other purposes," sufficiently indicates a provision that a failure to pay such taxes shall be a misdemeanor. Brown v. State, 73 Ga. 38. An act, entitled "An act to regulate, restrain, license or prohibit the sale of intoxicating liquors," sufficiently indicates a provision that ten per cent. of the license fees shall be paid into the state treasury. State v. Spokane Falls, 2 Wash. 40. The title, "An act to amend ch. 92 Gen. Sts., entitled 'revenue and taxes,' the other hand, a title "to regulate the sale of intoxicating liquors, and provide against evils resulting therefrom" has been held not. to include provisions prohibiting and punishing intoxication;1 and a title referring to a prohibition against the sale of spirituous liquors has been held not to support a provision prohibiting the sale of intoxicating liquors, the two words not being, in the opinion of the court, synonymous.2 Miscellaneous instances of titles. not broad enough to support provisions of statutes are set forth in the note.3 i. CRIMES AND CRIMINAL PROCEDURE.-Illustrations of what may be embraced under a general and comprehensive title are afforded by those decisions which hold that the title, "An act relative to crimes and offenses," is sufficient without specifying the particu embraces a provision to impose a fine on persons for selling liquor without license. Rosenham v. Com. (Ky.1886), 2 S. W. Rep. 230. The title of an original act, “Liquors," is sufficient to sustain provisions of an amendatory act regulating the sale. In re White, 33 Neb. 812. The title. "An act to prohibit the sale of intoxicating liquors within certain limits," will sustain a provision prohibiting the sale of " Plantation Bitters" or other intoxicating bitters under the name of patent medicine. Howell v. State, 70 Ga. 224; 51 Am. Rep. 259. The title, "An act to provide a local option law for the incorporated cities, towns and villages of this state," sufficiently indicates a proviso that the act shall not apply to a city, town or village in which the sale of ardent spirits shall thereafter be prohibited by legislative enactment. State v. Chester, 18 S. Car. 464. The title, "An act to amend acts relating to the practice of pharmacy," may contain provisions amending the laws authorizing the sale of liquors for different purposes. State v. Aulman, 76 Iowa 624. 1. State v. Young. 47 Ind. 150. 2. McDuffie v. State, 87 Ga. 687. 3. Insufficient Titles of Liquor Acts.A provision prohibiting the sale of intoxicating liquors within a specified limit, is not included within the title, "An act to regulate the sale of spirituous liquors." People v. Gadway, 61 Mich. 285; 1 Am. St. Rep. 578. The title, "An act to authorize police juries to make such regulations as they may deem proper to prohibit or regulate the sale, barter or exchange of intoxicating liquors or merchandise on Sunday," does not indicate a pro vision that violations of such ordinances shall be considered misdemeanors, and that the penalties therein prescribed shall be enforced by indictment orinformation. State v. Baum, 33 La. Ann. 981 ; overruling State v. Bott, 31 La. Ann. 663; 33 Am. St. Rep. 224. The title, "An act to regulate the sale of spirituous, malt, and vinous liquors," is insufficient to support an amendment increasing the license tax for the sale of such liquors, the effect of such amendment being to alter the charters of all the cities of the state. State v. Wright, 14 Oregon 365. The title, "An act to establish a separate school district, and for the appointment of a board of trustees for such school district,with certain powers and privileges," is not sufficient to embrace a provision that no license for the sale of spirituous liquors in the district shall be granted to any person without the recommendation of the board of trustees as to his moral fitness. Glenn v. Lynn, 89 Ala. 60S. The title, "An act to amend an act incorporating a town," which latter act merely authorizes the collection of a tax for selling liquors, is not sufficient to sustain a provision in the amendatory act prohibiting the sale of intoxicating liquors. Ex parte Cowert, 92 Ala. 94. The title, "An act to prohibit the issuing of licenses in certain boroughs," does not sufficiently indicate provisions imposing a penalty for selling liquor in said boroughs. Čom. v. Frantz, 135 Pa. St. 389. The title, To provide for licensing boats, hacks, and other vehicles by incorporated camp-meeting associations and seaside resorts and for the better government of the same," will not sus. lar crimes and offenses provided for in the act1 and that the titles, "Crimes and Criminal Procedure," and "An act to establish a code of criminal procedure,"3 may comprehend all matters relating to the definition and punishment of crimes and to criminal prosecutions. Miscellaneous instances where statutes have been sustained are given in the note.a tain provisions regulating the manufacture and sale of liquor at such resorts. Grover v. Ocean Grove Campmeeting Assoc., 45 N. J. L. 399. It was held in Lauer v. State, 22 Ind. 461, that the title, "An act to regulate and license the sale of intoxicating liquors, and providing penalties for the violation thereof," could not embrace a section relating to the jurisdiction of courts, and to the practice in prosecutions for offenses against the statute. Overruled, however, in Hingle v. State, 24 Ind. 2S, and Reams v. State, 23 Ind. III. 1. Crimes and Criminal Procedure Titles Sufficient.-State 7. Dubois, 39 La. Ann. 676; State v. Taylor, 34 La. Ann. 978. 2. State v. Brassfield, 81 Mo. 151; 51 Am. Rep. 234. 3. Woodruff v. Baldwin, 23 Kan. 491, in which case the title was held sufficient to embrace provisions relating to the care and custody of estates of convicts. It was contended here that the expression "criminal procedure" was broad enough to include not merely every proceeding in the prosecution of crime, but any proceeding connected with or directly caused by the crime, and aiming at the adjustment of rights disarranged by it, and that the expression was broader than the phrase "proceedings in criminal cases." This contention was sustained by the court. Under the title, "An act to amend the code," provisions may be embraced extending the definition of the crime of embezzlement so as to embrace persons and transactions not mentioned therein. Heller v. People (Colo. 1892), 31 Pac. Rep. 773 24 The title, "An act to amend chapter entitled 'criminal code,'" is sufficient, though the title of the act intended to be amended be "an act concerning criminal jurisprudence." Heller v. People (Colo. 1892), 31 Pac. Rep. 773 The title, "An act to add a new section to art. of the Code of Gen. Public Laws, entitled 'crimes and punish ment,' sub-title Rivers,'" sufficiently embraces a provision prohibiting the deportation of sand from the bed of a certain river, and prescribing a punishment therefor. State v. Norris, 70 Md. 91. 4. Miscellaneous Instances of Valid Criminal Statutes. The object of a statute providing punishment for offenses committed by slaves has been held sufficiently indicated by the title "An act relative to slaves." State v. Henry, 15 La. Ann. 297. The title, "to provide for the detection and conviction of all forgers of land titles," will support provisions prescribing the offense, its punishment, and the procedure. Johnson v. State, 9 Tex. App. 249, citing English v. State, 7 Tex. App. 171; Albrecht v. State, 8 Tex. App. 216; 34 Am. Rep. 737. A provision, that "Whoever shall willfully violate a contract upon the faith of which money or goods have been advanced" shall be punished, etc., is not indicated by the title,"To enforce labor contracts, and to provide a penalty for the willful violation thereof." State v. Pierson (La. 1892), 10 So. Rep. 400. The title, "An act to protect females of immature age and judgment from licentiousness," sufficiently indicates a provision making carnal intercourse with a female under the age of seventeen years a felony. Holton v. State, 28 Fla. 308. A statute "To regulate the sale or disposal of opium" and to prohibit the keeping of places of resort for smoking or otherwise using that drug," is not unconstitutional as embracing more than one subject. State v. Ah Sam, 15 Nev. 27; 37 Am. Rep. 454. The title, "An act to prohibit the fraudulent transfer of property and to declare the same a crime and to prescribe the punishment thereof," comprehends a provision making the sale and transfer, secretion, incumbrance, or disposal of property with intent to defraud creditors, an offense. Herold v. State, 21 Neb. 50. 66 The title, Dram shop-Gambling |