furnishing to the district clerk, to be filed by him, a certificate of regular attendance in such institute, signed by the person conducting the same. (Vol. 1, p. 309.) SECTION 1684. All notes, drafts, bills of exchange, or other negotiable paper, maturing on Sunday, or upon any legal holiday, shall be due and payable on the next preceding secular day. (Vol. I, p. 997.)

***

SECTION 2775In case of exigency, any injunction may be granted, and by direction of the court or judge, may be served on Sunday, or on a legal holiday. (Vol. 2, p. 1606.)

SECTION 137 6. The Governor is hereby authorized to set apart, by proclamation, one day in each year, to be observed as a tree planting, or arbor day, requesting all public schools and colleges, to observe the same by suitable exercises, having for their object, the imparting of knowledge of horticulture, in the department known as arborculture, and the adornment of school and public grounds. (Vol. I, p. 188.)

DRUMMOND, J., gives the following history of the Statutes of Wisconsin

The statute in relation to the 22d of February and 4th of July, was passed in 1861; but when there was legislation, in 1862, as to the 25th of December and Ist of January, there was no prohibition in relation to the Courts, except what might be inferred from the fact that they were declared holidays. It was not till afterwards (1869) that it was declared that when the day for the meeting of the Court should fall upon a legal holiday, it should adjourn to the following day. The natural conclusion would seem to be, that when the State Legislature, in 1861, legislated in relation to the 22d of February and 4th of July, and made prohibitions, and then again legislated, in 1862, as to the 25th of December and Ist of January, the prohibitions should not, by construction merely, be enlarged There does not seem to be any Statute of this State, which, when fairly considered, declares that no official Act shall be performed on a holiday. In referring to holidays, I do not intend to include Sundays, as to which there is considerable prohibitory legislation by this State, affecting business, public and private labor, amusements, and the service of civil process: (DRUMMOND, J. In re Worthington (1877), U. S. Cir. Ct., W. Dist. Wis. 7 Biss. 457, 458, 459.)

Wyoming Revised Statutes, in force January 1, 1887, provide

SEC. 1430. The first day of January, the twenty-second day of February, the thirtieth day of May, the fourth day of July, the day that may be appointed by the President of the United States as the annual thanksgiving day, and the twenty-fifth day of December of each and every year, are hereby declared legal holidays in and for the Territory of Wyoming. (p. 394.)

Wyoming also by an Act relating to negotiable instruments, and for other purposes, approved March 9, 1888, provides

SEC. 66. The first day of January, the twenty-second day of February, the thirtieth day of May, the fourth day of July, the twenty-fifth day of December,

and any day appointed by the Governor of the Territory or the l'resident of the United States, as a day of fast or thanksgiving, and any other day made a legal holiday by law, shall for all purposes whatsoever of presentment for payment, 'presentment for acceptance, and the protesting or the giving of notice of nonacceptance, or of non-payment, of all negotiable instruments, be considered as legal holidays; and if the first day of January, the twenty-second day of February, the thirtieth day of May, the fourth day of July, or the twenty-fifth day of December, or any other legal holiday shall fall upon Sunday, the Monday following shall be a legal holiday within the meaning of this article. (Laws, p. 153.)

SEC. 62. Except as otherwise provided in this article, the three days following the day on which a negotiable instrument becomes due by its terms, are allowed as days of grace, unless the last of such days is Sunday or a legal holiday, in which case the next preceding business day shall be the last day of grace allowed. (Id.)

SEC. 65. A negotiable instrument, on which days of grace are not allowed, which by its terms matures on Sunday or on a legal holiday, is payable on the next preceding business day. (Id.)

CHAPTER 87. AN ACT authorizing the Governor to designate arbor day and encourage tree planting. (Approved March 9, 1888.)

SECTION 1. The Governor shall annually, in the spring, designate by official proclamation, an arbor day, to be observed by the schools, and for economic tree planting, and the same shall be a legal holiday. (Laws, p. 183.)

IX. SUMMARY OF THE STATUTES.

A proper conclusion to the several statutes themselves will be a classification and review of some of their provisions, with a view to ascertain their uniformity. And, first, the enquiry is, what days are accounted legal holidays?

January First, or New Year's Day, is a legal holiday in all the States, except Arizona, Arkansas, Kentucky, Massachusetts, New Hampshire, Rhode Island, Utah and Washington. January Eighth, or the Anniversary of the Battle of New Orleans, is a legal holiday in Louisiana alone.

February Third, see Shrove Tuesday, infra.

February Twelfth is a legal holiday in Louisiana.

February Twenty Second, or Washington's Birthday, is a legal holiday in all the States, except Arizona, Arkansas, Iowa, Kansas, Mississippi, New Mexico, Utah and Washington (!). March Second, or the Anniversary of Texan Independence, is a legal holiday in that State alone.

March Twentieth, see Good Friday, infra.

April Twenty-first is a legal holiday in Texas only.

April Twenty-second, or Arbor Day, supra, p. 154.

April Twenty-sixth, known as Decoration Day in the States. where it is observed, is a legal holiday in Alabama and Georgia.

May Tenth is a legal holiday in North Carolina alone.

May Twentieth, or the anniversary of the Mechlenberg Declaration of Independence, is a legal holiday in North Carolina alone; as Memorial Day is a legal holiday in Tennessee.

May Thirtieth, or Decoration Day, is a legal holiday in all the States, except Alabama, Arizona, Arkansas, Maryland, Mississippi, Missouri, Montana, New Mexico, North Carolina, South Carolina, Texas, Utah, Virginia, Washington and West Virginia.

June (the first Saturday in), is a legal holiday in Oregon. under the name and title of Labor Day.

July Fourth, or Independence Day, is a legal holiday in all the States and Territories, except Arizona and Utah.

September First, or Labor Day, is a legal holiday in

Massachusetts,

Nebraska,

New York,

[Oregon (supra).] Pennsylvania.

September Ninth is a legal holiday in California.

December Twenty-fifth, or Christmas Day, is a legal holiday in all the States and Territories, except Arizona.

Arbor Day is merely observed in Pennsylvania, Illinois and Michigan (see the statute) when proclaimed by the Governor, but is a legal holiday in

California,

Dakota,

Election Day, when the election is held throughout the

State, is a legal holiday in

Fast Day, annual or special, is a legal holiday in

Good Friday, which may happen as early as the twentieth of March, and as late as the twenty-third of April (see the Tables in the front of the Book of Common Prayer), is a legal holiday in

Alabama,
Louisiana,

Maryland,

Minnesota,
Pennsylvania.

Inauguration Day, when the President of the United States takes his oath of office, is a legal holiday in the District of Columbia.

Saturday Afternoon holidays are established by law in New York.

Shrove Tuesday, or Mardi Gras, is a legal holiday in Alabama and Louisiana.

Special days set apart by the Governor of the State, or by the President of the United States, and generally for religious observances, in

Thanksgiving Day is a legal holiday in all the States and Territories, except Arizona, Arkansas and Utah.

Holidays are generally appointed by the President of the United States, or the Governor of the State, but Georgia is unique in also allowing "any municipal authority" to appoint days of "thanksgiving, or fasting and prayer, or other religious observances." So far as localizing the holiday, New York now authorized her governor to limit religious observances to particular places or sections.

Second, the enquiry may be, on what day is a variable holiday to be held, when it would happen on a Sunday? It is transferred to the following Monday in all except the following States; that is, Arizona and Arkansas; but Pennsylvania is unique in following the general rule in all cases except when the thirtieth of May falls upon a Sunday, then Decoration Day is observed on Saturday the twenty-ninth. Rhode Island agreed with Pennsylvania until 1886.

Appeals are to be entered in Georgia, within four days after the adjournment of the Court in which the judgment was entered, but Sundays and legal holidays are excluded from the computation: See page 142.

Appearance in Court, on a legal holiday is expressly excused, by statute in Iowa.

Court, or law, days are expressly transferred by statute to the next law day, when falling upon a legal holiday in Colorado and Michigan.

Days of Public Rest is the statutory term in Louisiana for legal holidays.

Judicial proceedings are forbidden, with certain limitations in

Legislative action in the form of ordinary business is for

bidden in Massachusetts.