radioactive elements would be deposited in the bones, spleen, and liver. In the fatal case which came under the observation of the writers the patient, who was 35 years old, had worked as a dial painter from October, 1917, to March, 1925. In 1923, following instructions given her at that time, she stopped pointing her brushes, at which time she was well except for neuralgia-like pains in the left leg. These pains later became so severe that she was obliged to use a cane, and in March, 1925, she developed a condition simulating pyorrhea and gave up work as a painter although she was in fair health until June (three weeks before death), when she noticed that she bruised easily. One week later her teeth became sore, the gums bled, and she was very weak. She was admitted to the hospital one week before her death, at which time she was acutely ill with a high temperature. There were marked lesions of the mouth and gums with bleeding and there was beginning necrosis of the soft palate, gums, and cheeks. Electrometer tests were made while the patient was still living as the occupational history and the clinical and pathologic picture indicated that the cause of her illness was radioactivity. These tests were made to determine whether there was penetrative radiation from her body and emanation in the expired air and the results of both were positive for radioactivity. Electrometer tests after death, on viscera and bones, showed small but definite penetrative radioactivity in the liver, spleen, kidneys, heart, and marrow from some of the bones, while there was considerable radioactivity in the lower jaw and both femurs. The tests were made for both gamma and alpha rays, and showed positive gamma radiation to be present in the organs, while alpha radiation was most marked from the spleen, bone marrow, and the outer layer of bone, and the liver. Röntgen-ray dental films were attached by metal clips to some of the bones and in six weeks' time there were exact shadowgrams of the metal clips, while a definite exposure of film with hazy shadowgrams was secured in 60 hours on a film attached to the lower jawbone. While this case in certain respects resembled pernicious anemia the writer says: As to the etiology, we feel that we have proved by the demonstration and measurement of radioactive substances in the body during life, in the expired air and in the organs after death, that the anemia in this case is dependent on the ingestion, long before, of radioactive paint, and that it is caused by the actual deposits in the spleen, bones, and liver of radium and mesothorium with their decayed products. For the foregoing reasons we have designated this anemia as a "rapid anemia of the pernicious type due to radioactivity." Radioactivity in the bones is very clearly shown by the exposure on the dental films. A case of chronic anemia of the pernicious type with extensive necrosis of the lower jaw in a person still living was also under the observation of the writers. This case was that of a woman 24 years of age who had worked for seven years as a dial painter, during which time she pointed brushes with her lips. This patient, who was in the hospital, had a persistent progressive necrosis of the lower jaw beginning two years before. Her temperature, except for periodic rises, was usually kept nearly normal through the frequent use of mouth washes and expert dental care. There was, however, a spontaneous fracture of the jaw with necrotic perforation of the hard palate. The electrometer tests of the expired air of this patient showed positive radioactivity. An account is also given of a woman aged 26 who had been employed both as a dial painter and as an instructor and who showed definite radioactivity although she was still in good physical condition. She had always used very good brushes and had not pointed them as frequently as was common among the other workers. The electrometer tests of her expired air, however, showed that there was emanation from both mesothorium and radium in measurable quantities, these tests being made long after she had given up work with the radioactive substance. In view of this fact it is considered probable that although her present condition is good the active deposits of insoluble products of radium and mesothorium in her bones, spleen, and liver, which are constantly bombarding her bloodforming centers, may eventually cause either an acute fatal anemia or a more chronic anemia with or without local lesions and bone necrosis. In summing up the deleterious effects of exposure of the human body to radioactive elements there are four ways given in which there may be such exposure. Penetrative or external radiation may produce harmful effects as a result of overexposure or long-continued exposure by means of the Röntgen rays and radiation by radium and its allied products; many cases of fatal anemia among radium workers and radiologists have been recognized by clinicians as due to such exposure. The inhalation of dust containing radium or the inhalation of emanation is another exposure hazard which is connected with certain work in the radium industry, such as tubing and retubing of partly aged radium, repairing needles, plaques, and containers, the preparation of radium and mesothorium and their decaying products for the manufacture of luminous paint, etc. Death from anemia in which this mode of entry was the cause have been recorded. Swallowing radioactive substances, as in the industry under consideration, produces both anemia and local lesions in the form of bone necrosis, and the intravenous injection of radioactive substances which is sometimes done in the treatment of certain diseases results in an accumulation of these elements in the body. The radioactive elements when introduced into the body emit "so-called positive, negative, and neutral (gamma) radiations of which positive charged alpha particles represent over 80 per cent of the total radium energy." The conclusions reached by the writers in summing up the results of the experiments and the clinical study of these cases are that this is the first time these anemias have been actually proved to be due to the ingestion of radioactive elements and that the necrosis of the jaw, which forms an important lesion in this disease, is due to local irritative radiation caused by clinging particles of radioactive substances on the gums, teeth, and roof of the mouth. The increased virulence of bacteria when exposed to small amounts of radioactivity is said to be a subject which has not yet been sufficiently investigated. This is believed to be the first time that radioactivity has been demonstrated in the human body during life by means of electrometers, although the presence of radium, mesothorium, and their decayed products has been demonstrated in previous experiments in the organs after death. The importance of this means of determination of the presence of radioactive elements in the body is pointed out as it can be shown by this means months and years before clinical symptoms develop. Check tests on normal individuals have failed to show any radioactivity. After these radioactive elements are once deposited in the body there is no treatment known by which they can be eliminated, changed, or neutralized. They decrease in amount in varying periods of time according to their individual characteristic decay, radium taking 1,750 years and mesothorium 6.7 years to reach one-half of its original activity. LEGAL AID Need for Free Legal Aid 1 By WILLIAM HOWARD TAFT, CHIEF JUSTICE OF THE UNITED STATES SUPREME COURT Τ HE social changes in our people, the transfer from country to urban life of the majority, the influx of peoples of foreign birth, and the great increase in the cost of litigation to persons taking part in it have together seriously impaired the usefulness of our courts to those who most need their protection. Our just pride in the institutions derived from the common law, embodied in our Federal and State Constitutions, is much of it in the maintenance of individual rights. They are chiefly valuable in enabling the individual, without dependence on executive favor, to maintain and defend in the courts his life, liberty, and property. The peculiar value of our constitutional Bill of Rights is not in high-sounding declarations of substantive right, whose preservation is generally enjoined upon all Government authority in every country. They are to be found in the fundamental law of most States of the world and are too often more honored in the breach than in the observance. The real practical blessing of our Bill of Rights is in its provisions for fixed procedure securing a fair hearing by independent courts to each individual. It makes these adjective rights inviolable. The right of trial by jury, the right to be defended against unreasonable searches and seizures, the right requiring due process in the deprivation of life, liberty, or property illustrate the practical realization in AngloSaxon liberty of vesting the power in the individual as an individual to obtain, without cultivating the favor of official authority, fixed judicial procedure to protect his substantial rights. But if the individual in seeking to protect himself is without money to avail himself of such procedure the Constitution and the procedure made inviolable by it do not practically work for the equal benefit of all. Something must be devised by which everyone, however lowly and however poor, however unable by his means to employ a lawyer and to pay court costs, shall be furnished the opportunity to set this fixed machinery of justice going. It was the consciousness of the harshness of the circumstances in shutting poor people out of the opportunity to appeal to courts that induced Arthur von Briesen, that philanthropic leader of the bar, to organize and set on foot legal aid societies. Such societies have increased in various parts of the country and differ some in their organization, in the sources of their maintenance, whether by the bar, or by social aid societies, or by municipalities. The success of them and the real good that they have done are a testimony to the high spirit of many lawyers and reflect credit on the bar. Without expressing a final personal conclusion on the 1 From the preface to Bulletin 398 of this bureau; Growth of legal aid work in the United States. Washington, January, 1926. subject, it seems to me that ultimately these instrumentalities will have to be made a part of the administration of justice and paid for out of public funds. I think that we shall have to come, and ought to come, to the creation in every criminal court of the office of public defender, and that he should be paid out of the treasury of the county or the State. I think, too, that there should be a department in every large city, and probably in the State, which shall be sufficiently equipped to offer legal advice and legal service in suits and defenses in all civil cases, but especially in small claims courts, in courts of domestic relations, and in other forums of the plain people. A great deal has been done to promote the achieving of justice for the poor and unfortunate in workmen's compensation acts. They have expedited just recoveries and have relieved the burdened courts, enabling them to dispose of other litigation heretofore long delayed. It may be necessary, in order to prevent unwise or improper litigation, to impose a small fee for the bringing and carrying through of a suit by such free agencies. The department of free legal aid should be charged with the duty of examining every applicant and looking into his actual poverty and necessity and the probably just basis for his appeal. It may be well to unite both civil and criminal cases and make the public defender a part of the general department of free legal service. The growth of these legal aid organizations is the most satisfactory proof of their necessity. Growth of Legal Aid Work in the United States OVERTY obstructs the way of complete legal justice and "it will continue to do so until public opinion forces a radical overhauling of our archaic system of court costs and fees," according to Bulletin No. 398 of the United States Bureau of Labor Statistics, on the Growth of Legal Aid Work in the United States. After a discussion on the difficulties the laborer faces when he seeks legal justice, the authors of this report, Mr. Reginald Heber Smith of the Boston Bar, and Mr. John S. Bradway of the Philadelphia Bar, trace the origin and development of the agencies designed to improve the position of the wage earner before the law. Such agencies include the small claims court, conciliation tribunals, industrial accident boards and commissions, administrative officials, the defender in criminal cases, and legal aid organizations. A brief summary is given here of the character, scope, and operation of these remedial services. Small Claims Court A SMALL claims court is a court of law having a quick, simplified, and inexpensive procedure and jurisdiction over small cases, such jurisdiction in most States being over matters involving on an average $50 or less. Its decisions and judgments are as binding and as enforceable as those of any other court in the country. The penalty for refusing to obey the summons of a small claims court is a default. The cases are heard by a judge whose decision |