of Kings, and extended to the county provisions relating to the exemption of charitable institutions from taxation. The object of the amendment was to extend the original statute from the city of Brooklyn to the whole county. The amendment of the title of the original act was a necessary element of this object, and was not another subject. Dyker Meadow Land & Improv. Co. v. Cook (1896) 3 App. Div. 164, 38 N. Y. Supp. 222.

1887, chap. 544, "to Amend Chapter 776 of the Laws of 1870, Entitled 'An Act to Amend an Act Entitled "An Act to Provide for the Incorporation of Villages," Passed December 7, 1847, and the Several Acts Amendatory Thereof, So Far as the Same Relate to the Village of Mount Vernon, in the County of Westchester; and to Declare, Enlarge, and Define the Powers and Duties of the Officers of Said Village, and to Confirm and Extend the Powers of the Corporation of Said Village."" All parts of the act were germane to the title. People ex rel. Lynch v. Duffy (1888) 49 Hun, 276, I N. Y. Supp. 896.

1887, chap. 205, "to Legalize the Acts and Proceedings of the Town Board, and the Town Board of Auditors of the Town of Attica, Wyoming County, in Relation to the Erection of a Certain Iron Bridge over the Tonawanda Creek, on Main Street, in the Village of Attica, in Said Town, and the Acts and Proceedings of the Annual Town Meeting of Said Town, Held on the 22d Day of February, 1885, in Relation to Said Bridge, and the Acts and Proceedings of George D. Miller as Highway Commissioner of Said Town in Relation to Said Bridge." A provision relieving the town from any obligation to pay the price fixed by a contract for the erection of a bridge, the proceedings in relation to which were ratified by the act, and authorizing the contractor to bring an action against the town to recover compensation for erecting such bridge, was held germane to the title. Wrought Iron Bridge Co. v. Attica (1890) 119 N. Y. 204, 23 N. E. 542.

1888, chap. 213, "to Ratify and Confirm Certain Proceedings of the Board of Trustees of the Village of Flushing." Irregular assessments were properly included under this title. People ex rel. Richmond v. Wilson (1888) 21 N. Y. S. R. 120, 3 N. Y. Supp. 326, affirmed in (1890) 121 N. Y. 684, 24 N. E. 1098.

1889, chap. 161, "in Relation to Public Improvements in the Town of Flatbush, and the Acquisition of the Rights of a Plank Road Company in Said Town." A provision authorizing the construction of a trunk sewer through the town of Flatlands to tidewater was

held germane to the title. Van Brunt v. Flatbush (1891) 128 N. Y. 50, 27 N. E. 973.

1889, chap. 291, “to Establish and Maintain a Water Department in and for the City of Syracuse," amended, 1890, chap. 314. The act contained numerous provisions intended to effectuate its purpose, but they were held fairly within the general subject, and germane to the title. Sweet v. Syracuse (1891) 129 N. Y. 316, 27 N. E. 1081, 29 N. E. 289.

1890, chap. 55, "to Incorporate the City of Gloversville." The city was erected out of a part of the town of Johnstown. The remainder of the original territory was continued as the town of Johnstown. The act was sustained. People v. Wilber (1891) 39 N. Y. S. R. 743, 15 N. Y. Supp. 435.

1890, chap. 523, "in Relation to the Office of Sheriff of the City and County of New York." It related to the sheriff's salary, to under sheriffs and deputies, numerous subordinates, office accounts, official bonds, etc. All these details were germane to the subject expressed in the title. New York v. Gorman (1898) 26 App. Div. 191, 49 N. Y. Supp. 1026.

1892, chap. 342, "to Establish a Local Court of Civil Jurisdiction in the City of Syracuse, to be Called the 'Municipal Court of the City of Syracuse,' and to Amend the Charter of Said City." The act abolished the office of justice of the peace, and repealed inconsistent acts. The general object of the act was to create an inferior local tribunal, and the abolition of justices' courts was consistent with this purpose. Curtin v. Barton (1893) 139 N. Y. 505, 34 N. E. 1093.

1893, chap. 537, "Providing for Ascertaining and Paying the Amount of Damages to Lands and Buildings Suffered by Reason of Changes of Grade of Streets or Avenues, Made Pursuant to Chapter 721 of the Laws of 1887, Providing for the Depression of Railroad Tracks in the 23d and 24th Wards in the City of New York, or Otherwise." The subject is the payment of damages sustained by the change of grade of streets. It is limited both as to territory and as to the scope of damages. are fairly germane to the title. People ex rel. Purdy v. Fitch (1895) 147 N. Y. 355, 41 N. E. 695.

All elements of the act

1894, chap. 146, "to Amend Chapter 147 of the Laws of 1864, Entitled 'An Act to Provide for the Erection of a Town Hall in the Town of Jamaica, in the County of Queens,' and Acts Amendatory Thereof." The original act provided for the erection of a town hall, but did not authorize the condemnation of land for this pur

pose. The amendatory act added a provision authorizing such condemnation. This was not an independent subject, but an incident of the general purpose of the act, and germane to the title. Jamaica v. Denton (1895) 70 N. Y. Supp. 837.

1895, chap. 975, "to Divide the Town of Watervliet in the County of Albany, and to Erect the Town of Colonie out of the Part Set Off from Said Town of Watervliet." It erected the town of Colonie, and provided a local government therefor, including the election of a supervisor and justices of the peace. The creation of a town government is necessary in the erection of a new town, and is germane to the general subject. "Where the legislature has power to enact a law, it has the power to embrace in that law everything which is either necessary or proper to make it a complete whole. It can embrace in it everything germane to the main subject of the enactment, and all necessary or proper details." Fort v. Cummings (1895) 90 Hun, 481, 36 N. Y. Supp. 36.

1896, chap. 178, "to Amend Chapter 686 of the Laws of 1892, Entitled 'An Act in Relation to Counties, Constituting Chapter 18 of the General Laws,' as Amended by Chapter 79 of the Laws of 1894, by Chapter 163 of the Laws of 1894, and by Chapter 742 of the Laws of 1895, Relating to Authorizing Towns to Borrow Money." The amendment applied exclusively to Queens county, and restricted the power to make contracts relating to the construction of highways. Assuming that the amendatory act is to be regarded as local so far as this provision is concerned, it was within the subject expressed in the title, although the particular county affected was not mentioned. Dunton v. Hume (1897) 15 App. Div. 122, 44 N. Y. Supp. 305, following People ex rel. Burroughs v. Brinkerhoff (1896) 68 N. Y. 259.

1896, chap. 520, "to Amend Chapter 53 of the Laws of 1879, Entitled 'An Act to Revise the Charter of the City of Auburn,' and the Several Acts Amendafory Thereof and Supplemental Thereto; to Change the Time for Holding Charter Elections in Said City, and to Provide for the Tenure of Office of the Officers of Said City, and of the Several Wards Therein." The act changed the time of holding city elections from spring to fall. All parts of the act related to affairs of the city and to its charter, and were properly included in the general subject. People ex rel. Stupp v. Kent (1903) 83 App. Div. 554, 82 N. Y. Supp. 172.

1896, chap. 772, "in Relation to the Office of the District Attorney of the County of Kings, Providing for the Election of District Attorney and the Appointment of Clerks, Stenographers, and County VOL. IV. CONST. HIST.-26.

Detectives for Said Office." It was claimed that a provision of this act repealing a former statute providing for county detectives was invalid because not expressed in the title. The title included county detectives, and the repeal of a former statute on the same subject was incidental to the general purpose of the act. People ex rel. Dee v. Backus (1896) 11 App. Div. 147, 42 N. Y. Supp. 899, affirmed in (1897) 153 N. Y. 686, 48 N. E. 1106.

1899, chap. 34, "for the Better Administration of Justice in the Town of Sweden, County of Monroe." The act abolishes the office of police justice in the village of Brockport, and establishes a like office for the town of Sweden, which includes the village. Both objects are germane to the main purpose, namely, the improvement of the administration of justice. People ex rel. Holmes v. Lane (1900) 53 App. Div. 531, 65 N. Y. Supp. 1004 1899, chap. 257, "in Relation to Clinton Avenue, in the Borough of Brooklyn, in the City of New York." The act widened Clinton avenue between certain points by adding 20 feet on each side, and which spaces were to be used, not for the purposes of travel, but as ornamental court yards for the benefit and improvement of said avenue. The act also included details relative to the acquisition of land for the improvement. The body of the act was germane to its general purpose, and valid. Re New York (1901) 57 App. Div. 166, 68 N. Y. Supp. 196, affirmed in (1901) 167 N. Y. 624, 60 N. E. 1108.

1901, chap. 33, "Relating to the Police Department of the City of New York; to Terminate the Terms of Office of the Police Commissioners of Said City; to Abolish the Office of Chief of Police in Said City; to Concentrate the Functions Theretofore Exercised by Such Commissioners and Chief in a Single Commissioner; to Provide for the Appointment and Removal of Such Commissioner and His Deputies; and to Enlarge the Powers Heretofore Exercised by Said Commissioners, and to Confer Such Enlarged Powers Upon Such Single Commissioner and His Deputies; to Transfer the Powers and Functions Heretofore Exercised by the Treasurer of the Police Board to the Comptroller of the City of New York; and to take from Such Commissioner the Control of the General Bureau of Elections, and to Abolish Such Bureau." "The act contains but one subject, the reorganization of the police force in the city of New York." The details all relate to the same subject, and are germane to the general purposes of the act as expressed in the title. People ex rel. Devery v. Coler (1903) 173 N. Y. 103, 65 N. E. 956.

STATUTES INVALID UNDER ARTICLE, 3, § 16.

1854, chap. 291, "to Release the Fishkill & Beekman Plank Road Company from the Construction of Part of Their Road, and for Other Purposes." It authorized the release and abandonment of certain parts of a road on specified conditions, permitted the company to relay the road with gravel instead of plank, and inflict penalties in relation to toll gates, and it also legalized the previous acts of the company. It was said in Fishkill v. Fishkill & B. Pl. Road Co. (1856) 22 Barb. 634, that all these provisions related to one general subject and might properly be included in one law; but the title was defective because it did not embrace the several elements of the subject. The words "and for other purposes" were excluded from consideration, because meaningless under the constitutional provision that the subject must be stated in the title. People v. Fishkill & B. Pl. Road Co. (1857) 27 Barb. 445.

1863, chap. 227, "to Enable the Board of Supervisors of the County of New York to Raise Money by Tax for the Use of the Corporation of the City of New York." Under it the head of the law department had the right, and it was his duty, to represent the mayor and common council in all legal proceedings. This part of the act was held to be entirely distinct from the subject expressed in the title, and therefore unconstitutional. Baldwin v. New York (1864) 42 Barb. 549, (1865) 45 Barb. 359, (1866) 2 Keyes, 387.

1863, chap. 361, "to Authorize the Construction of a Railway and Tracks in the Towns of West Farms and Morrisania." A provision authorizing the construction of a railroad in towns not mentioned in the title embraced another subject, and was void. The remainder of the act was sustained. Bohmer v. Haffen (1900) 161 N. Y. 390, 55 N. E. 1047.

1865, chap. 181, "to Amend Chapter 389 of the Laws of 1851," which was an act relating to the Rochester charter. The act under consideration authorized the Rochester common council to elect seven directors of the Rochester & Genesee Valley Railroad Company, instead of four, as under the previous statute. The title of the act does not indicate any part of the statute of 1851, which is sought to be amended. It was therefore defective, and the act was void. People ex rel. McConvill v. Hills (1866) 35 N. Y. 449.

1866, chap. 876, "to Enable the Board of Supervisors of the County of New York to Raise Money by Tax for the Use of the Corporation of the City of New York, and in Relation to the Expenditure Thereof." It contained a provision relieving the city from liability beyond the amount appropriated for a specific object, and prohibit