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Each syllabus paragraph in this volume is marked
with the topic and Key-Number sections under
which the point will eventually appear in the Amer-
ican Digest System.
The lawyer is thus led from that syllabus to the exact
place in the Digests where we, as digest makers, have
placed the other cases on the same point---This is the
Key-Number Annotation.

THE

NORTHWESTERN REPORTER

VOLUME 180

PERMANENT EDITION

COMPRISING

ALL THE DECISIONS OF THE SUPREME COURTS OF
MINNESOTA, MICHIGAN, IOWA, WISCONSIN
NEBRASKA, NORTH DAKOTA, AND

SOUTH DAKOTA

WITH KEY-NUMBER ANNOTATIONS

CONTAINING A TABLE OF NORTHWESTERN CASES IN WHICH REHEARINGS

HAVE BEEN DENIED

JANUARY 7 — FEBRUARY 25, 1921

ST. PAUL

WEST PUBLISHING CO.

1921

COPYRIGHT, 1921

BY

WEST PUBLISHING COMPANY

(180 N.W.)

NORTHWESTERN REPORTER, VOLUME 180

JUDGES

OF THE COURTS REPORTED DURING THE PERIOD COVERED

BY THIS VOLUME

IOWA-Supreme Court. SILAS M. WEAVER, CHIEF JUSTICE.1 WILLIAM D. EVANS, CHIEF JUSTICE.2

JUSTICES.
BENJAMIN I. SALINGER.
WILLIAM D. EVANS.
TRUMAN S. STEVENS.
THOMAS ARTHUR.
BYRON W. PRESTON.
SCOTT M. LADD.:
SILAS M. WEAVER.1
FREDERICK F. FAVILLE.
LAWRENCE DE GRAFF.

NEBRASKA-Supremo Court. ANDREW M. MORRISSEY, CHIEF JUSTICE.

ASSOCIATE JUSTICES.
CHARLES B. LETTON.
WILLIAM B. ROSE.
JAMES R. DEAN.
CHESTER H. ALDRICH.
GEORGE A. DAY.
LEONARD A. FLANSBURG.

MICHIGAN-Supreme Court.

NORTH DAKOTA-Supreme Court.
A. M. CHRISTIANSON, CHIEF JUSTICE.?
JAMES E. ROBINSON, CHIEF JUSTICE.S

JUDGES.
A. M. CHRISTIANSON.?
JAMES E. ROBINSON.S
RICHARD H. GRACE.
LUTHER E. BIRDZELL.
H. A. BRONSON.

JOSEPH B. MOORE, CHIEF JUSTICE.1 JOSEPH H. STEERE, CHIEF JUSTICE.

ASSOCIATE JUSTICES.
JOSEPH H. STEERE."
JOSEPH B. MOORE.1
FLAVIUS L. BROOKE."
GRANT FELLOWS.
JOHN W. STONE.
GEORGE M. CLARK.
JOHN E. BIRD.
NELSON SHARPE.
HOWARD WIEST.

SOUTH DAKOTA-Supreme Court.

MINNESOTA-Supreme Court. CALVIN L. BROWN, CHIEF JUSTICE.

ASSOCIATE JUSTICES. ANDREW HOLT. OSCAR HALLAM. JAMES H. QUINN. HOMER B. DIBELL.

SUPREME COURT COMMISSIONERS.

MYRON D. TAYLOR.
EDWARD LEES.

1 Ceased to be Chief Justice January 1, 1921.
? Became Chief Justice January 1, 1921.
3 Term expired.
• Took omce January 1, 1921.
Died January 21, 1921.
Appointed January 25, 1921, to succeed Flavius
L. Brooke.

(v)*

JAMES H. MCCOY, PRESIDING JUDGE.
SAMUEL C. POLLEY, PRESIDING JUDGE.10

JUDGES
JAMES H, MCCOY."
CHARLES S. WHITING.
ELLISON G. SMITH.
SAMUEL C. POLLEY.10
JOHN HOWARD GATES.

WISCONSIN-Supreme Court.
ROBERT G. SIEBECKER, CHIEF JUSTICE.

ASSOCIATE JUSTICES.
JAMES C. KERWIN.11
AAD JOHN VINJE.
MARVIN B. ROSENBERRY.
FRANZ C. ESCHWEILER,
WALTER C. OWEN.
BURR W. JONES.

i Ceased to be Chief Justice January 4, 1921.
& Became Chief Justice January 4, 1921.
• Ceased to be Presiding Judge January 3, 1921.
10 Became Presiding Judge January 3, 1921.
11 Died January 29, 1921.

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