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tending the execution to the cargo. But this order, from its very terms, left undetermined the question of liability of the cargo to the schooner. All that it did, says the court, "was to extend the execution from one property to another under local law, leaving the rights of the Sugar Products Company to be determined later by another tribunal.” This being so, the court was of opinion that the order was not an appealable one and accordingly remanded the cause "to be brought to judgment under local laws in proceedings not inconsistent with this opinion."

The contacts of two dissimilar systems of procedure and the process of their coalescence to a greater or less degree have at all times represented a phenomenon which is of peculiar interest for legal history. On a smaller scale there is being repeated in the case of the Virgin Islands what has taken place in the Philippines and Porto Rico. For the most part, we have wisely followed the enlightened policy which induces dominant peoples to leave intact as far as possible the judicial institutions of those who have come under their sovereignty. But it is not enough that this shall be the policy of legislation: without the requisite delicacy of touch on the part of appellate tribunals, the principle may be easily subverted. Hence, we note, with unalloyed satisfaction, the attitude reflected in the court's observation that “in an endeavor to exercise this jurisdiction in harmony with Danish law, yet consistently with laws of our own, as broadly prescribed, we have on occasion found it necessary—and a little difficult—to yield our conceptions of law and to conform our procedure in a measure to that of the appellate courts of Denmark” (The Edgewood, supra). In a situation of the

a present kind narrow-mindedness and lack of respect for institutions different from our own may work incalculable harm, both politically and procedurally. But an examination of the cases above noted convinces one that the people of the Virgin Islands and the government of the United States, alike, are fortunate in having the jurisdiction under discussion committed to a court which approaches the solution of the troublesome questions involved—all the more troublesome because of apparent awkwardnesses in translation of the records with a sympathetic appreciation of the foreign law and a desire to conform to its principles so far as the Constitution permits.

R. W. M.

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