The Seventh of the Pan American Conferences was held at Montevideo, the capital of Uruguay, from the 3d to the 26th of December last, so that it was impossible to have comments upon its activities appear in the January number of the JOURNAL. The undersigned is taking advantage of this opportunity to say a word on certain phases of Pan-Americanism, and the observations, in so far as they concern treaties or conventions, will be in the order in which they appear in the Final Act.

It is well settled in Anglo-American law that national courts are competent, in general, to adjudicate rights and duties with respect to all things or persons found within the territory which the process of the court controls. Exceptions find an especial justification in considerations of national or international convenience. A situation which seems to have been insufficiently considered, however, is presented by the case of the thing or person which has been seized or arrested abroad, in violation of international law, and brought within the state and thus within reach of the process of the state's courts. Should the courts be considered competent, on the basis of physical presence thus procured, to adjudicate in the usual way?

There is confusion in the doctrine of the responsibility of states for denial of justice, particularly where the “denial” consists in failure to operate the machinery of criminal justice.

Derivative citizenship may be defined as acquired citizenship; it is a status of nationality not fixed by birth, but conferred thereafter through the act of another. It is a form of indirect naturalization by operation of law. In the United States, nationality is acquired derivatively by foreign-born resident minors whose parents are naturalized, and prior to September 22,1922, it was acquired by alien women whose husbands were or became citizens.

The recent decision of the Supreme Court of the United States in Factor v. Laubenheimer and Haggard has broken new ground with reference to the interpretation of the extradition treaties between the United States and Great Britain, and it seems to deserve special consideration as a contribution to the law of extradition. Factor's extradition was requested by Great Britain on a charge of receiving certain sums of money, aggregating £458,500, known to have been fraudulently obtained. On the complaint of a British consul, Factor was taken into custody in Illinois, and a United States Commissioner in Illinois issued a warrant for his commitment pending surrender. On a return to a writ of habeas corpus, the District Court for the Northern District of Illinois ordered his discharge from custody, but this order was reversed by the Circuit Court of Appeals. Both the District Court and the Circuit Court of Appeals seem to have regarded extradition as possible only if the offense charged was a crime both by the law of Great Britain and by the law of Illinois; the District Court held that receiving money known to have been fraudulently obtained was not a crime by the law of Illinois, but a majority of the Circuit Court of Appeals, relying chiefly on Kelly v. Griffin, took the contrary view. On certiorari, the Supreme Court held that the offense charged was an extraditable crime even if it is not punishable by the law of Illinois, the opinion being written by Justice Stone. Justice Butler was joined in a vigorous dissenting opinion by Justices Brandeis and Roberts.

In connection with the war conditions which existed in Turkey from 1914 to 1922, a number of international claims arose against the Government of Turkey, including a large number on behalf of citizens of the United States. Negotiations with respect to these latter claims were undertaken by American and Turkish representatives, and on December 24, 1923, the American High Commissioner at Constantinople (Rear Admiral Mark L. Bristol), and the delegate of the Turkish Ministry of Foreign Affairs (Dr. Adnan Bey), entered into a claims agreement by an exchange of notes which provided.

While the Eighteenth Amendment and the Volstead Act were in force there was much debate on the question as to whether international law required that foreign diplomats be exempt from their operation. Administrative regulations provided for such exemption, but an interesting article by Mr. Lawrence Preuss argued forcibly that no such exemption was required. The matter has become wholly academic now, although it might become practical again should Congress ever reenact a prohibition law for the District of Columbia. None the less, it may be instructive to call attention to what seems to be the only direct precedent in international practice, a precedent which has apparently remained buried until now.

The Institut de Droit International has granted the John Westlake prize, established by Mr. James Brown Scott in memory of his mother, to Dr. Anton Roth of Gross-Auheim a/Main, author of an essay prepared upon the subject of “A study of the rules applicable, in cases of international responsibility, to the measure of damages caused to private persons on the territory of a foreign state. The question must be developed principally with regard to international practice and the decisions of international tribunals.”