The causes of strikes in 1898 and their results are shown in the two following tables:

Of the 256 strikes, 157, or 61 per cent, were due to wage disputes; 19, or 8 per cent, to disputes regarding hours of labor, and 80, or 31 per cent, to other causes. Taking the number of strikers as the basis, it is shown that of the 35,705 reported, 23,681, or 66 per cent, struck on account of wage disputes; 1,799, or 5 per cent, on account of hours of labor, and 10,225, or 29 per cent, for other reasons.

With regard to the results of strikes in 1898, it is shown that 27 per cent of the strikes, involving 27 per cent of the strikers, were successful; 27 per cent of the strikes, involving 31 per cent of the strikers, were partly successful, and 46 per cent of the strikes, involving 42 per cent of the strikers, were failures.

The following table gives a comparison of the proportionate results of strikes during a period of years:

The percentage of strikes which failed was greater in 1898 than any other year during the period, except 1892, and the percentage of successful strikes was smaller than at any time except 1879-1891 and 1892. In the following table the total strikes, strikers, and working days lost in 1898 are given by occupations:

STRIKES, STRIKERS, AND WORKING DAYS LOST, BY OCCUPATIONS, 1898.

The number of strikes in agriculture, as in the other industries, was greater in 1898 than in the preceding year, there being 36, as against 12 strikes in 1897. The 36 strikes involved 5,376 men, 2,576 women, and 543 children, or a total of 8,495 persons. Nine of the strikes were successful, 13 were partly successful, and 14 failed.

LOCKOUTS.-Eighteen cases were reported in 1898 where proprietors closed their establishments for the purpose of accomplishing certain objects, but of these only 4 were directed against employees and could properly be called lockouts. The 4 lockouts affected 334 employees. Of these lockouts 2 were successful, 1 was partly successful, and in the other the result was not reported.

COUNCILS OF PRUDHOMMES.-On December 31, 1898, there were 81 councils of prudhommes, or councils for the conciliation and arbitration of labor disputes, instituted according to law. This was an increase of 22 during the year. Only 32, however, performed their functions. at the close of the year. During the year 11 cases were reported where they had occasion to intervene in strikes.

NORWAY.

Tabeller vedkommende Arbeidslønninger i Aarene 1890 og 1895. Norges officielle Statistik. Tredie Række No. 321. Udgivne af det statis

The present work, which is one of a series of publications of the Norwegian statistical bureau, consists of a number of tables, showing, by occupations and localities, the wages of agricultural and other rural laborers and of working people in cities and towns. The detailed tables show the wages for the years 1830 and 1895, while summary tables show average wages at 10-year periods from 1850 to 1870, and at 5-year periods from 1870 to 1895. Tables are also given showing the wages of railway and road laborers for each year from 1871 to 1898, and of employees in the fire and engineering departments of the city of Christiania from 1868 to 1898.

DECISIONS OF COURTS AFFECTING LABOR.

[This subject, begun in Bulletin No. 2, has been continued in successive issues. All material parts of the decisions are reproduced in the words of the courts, indicated when short by quotation marks and when long by being printed solid. In order to save space, immaterial matter, needed simply by way of explanation, is given in the words of the editorial reviser.]

DECISIONS UNDER STATUTORY LAW.

CONSTITUTIONALITY OF STATUTE-CITY ORDINANCE-HOURS OF LABOR-City of Seattle v. Smyth et al., 60 Pacific Reporter, page 1120.-A complaint was filed in the superior court of King County, Wash., against Sidney Smyth and others, charging them with violation of an ordinance of the city of Seattle. The defendants filed a demurrer to the complaint, which was sustained by the court, and the city then appealed the case to the supreme court of the State, which rendered its decision April 6, 1900, and sustained the action of the lower court, declaring the ordinance, which made it unlawful to require or permit any day laborer or mechanic to work on the public works more than eight hours in a day, to be unconstitutional. From the opinion of the court the following is quoted:

Statutes and ordinances similar in character have been held unconstitutional by many courts, and we have not been cited to a single case wherein their constitutionality is asserted. The principle upon which they are held to be unconstitutional is that they interfere with the constitutional right of persons to contract with reference to compensation for their services where such services are neither unlawful nor against public policy, nor the employment such as might be unfit for certain classes of persons-as females and infants. "Every person sui juris has a right to make use of his labor in any lawful employment on his own behalf, or to hire it out in the service of others. This is one of the first and highest of civil rights." (Cooley, Torts, 2d ed., p. 326.) The judgment of the superior court is affirmed.

EMPLOYERS' LIABILITY-CONSTITUTIONALITY OF STATUTE LIMITING AMOUNT OF DAMAGES TO BE RECOVERED-Hamman v. Central Coal and Coke Co., 56 Southwestern Reporter, page 1091.-This action was brought against the above-named company by one Mary Hamman to recover $10,000 damages for the death of her husband, a coal miner in the employ of said company at date of his injury and death,

which death was alleged to have been caused by the negligence of said company. Action was brought under section 7074 of the Revised Statutes of Missouri, 1889, as amended by act approved April 23, 1891, page 182, acts of Missouri of 1891. Said section as amended reads as follows:

For any injury to persons or property occasioned by any violation of this article [regulating mines] or failure to comply with any of its provisions, a right of action shall accrue to the party injured for any direct damages sustained thereby; and in case of loss of life by reason of such violation or failure as aforesaid, a right of action shall accrue to the widow of the person so killed, his lineal heirs or adopted children, or to any person or persons who were, before such loss of life, dependent for support on the person or persons so killed, for a like recovery of damages sustained by reason of such loss of life or lives: Provided, That all suits brought under this article shall be commenced within one year after any cause of action shall have accrued under this article and not afterwards; And, provided further, That any person entitled to sue under this section for loss of life or lives may recover any sum not exceeding $10,000.

The amendment made to this section by the act of April 23, 1891, above referred to, is contained in the last proviso of the section, which allows one entitled to sue for damages under the section to recover any sum not exceeding $10,000. In the circuit court of Bates County, Mo., where the trial of the case was had, a judgment was rendered for the plaintiff and the defendant company appealed the case to the supreme court of the State, which rendered its decision May 8, 1900, and affirmed the judgment of the lower court. Among the many points raised on this appeal was the constitutionality of the amendment to section 7074, above referred to, which was upheld by the supreme court in the following language, which is quoted from the opinion of the court as delivered by Judge Burgess in division and approved by the court in banc :

There is no more important question presented on this appeal than that with respect to the constitutionality of the act of 1891 (page 182, laws of 1891) amending section 7074, Rev. Sta., 1889, which prescribes the measure of the recovery of damages in cases of this character, which defendant contends is class legislation, and in conflict with section 53, art. 4, of the constitution of this State, which provides, "that the general assembly shall not pass any local or special law granting to any individual any special or exclusive right, privilege or immunity," and therefore void. The law of which the act in question is amendatory pertains to all kinds of mines and mining in this State, and regulates them with respect to providing safeguards for the protection of employers [employees] while at work in mines, and its constitutionality is not questioned; but the argument is that the amendatory act, which entitled the widow and children of anyone killed by the negligence of his employer while engaged at work in a mine to recover any sum not exceeding $10,000 damages therefor, while under the general damage act they are only entitled to recover an amount not exceeding $5,000 in such circumstances, is