Joseph F. (Joseph Fitz) Randolph.

A treatise on the law of commercial paper; containing a full statement of existing American and foreign statutes, together with the text of the Commercial codes of Great Britain, France, Germany and Spain (Volume 1) online

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Online LibraryJoseph F. (Joseph Fitz) RandolphA treatise on the law of commercial paper; containing a full statement of existing American and foreign statutes, together with the text of the Commercial codes of Great Britain, France, Germany and Spain (Volume 1) → online text (page 46 of 125)
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property or labor to be due, "are negotiable with all the incidents of negotia-
bility, whenever it is manifest from their terms that such was the intent of
, the maker, but the use of the technical words 'order' or 'bearer' alone will not
manifest such intention." Code, § 3045. In KENTUCKY all bonds, bills,
and notes for money or property are assignable subject to defense. Bills,
drafts, or checks payable in bank notes or currency or other funds are ne-
gotiable as if for money, except that only the value of the currency mentioned
can be recovered. St. § 4745. In MARYLAND, the British statute, 3 & 4
Anne, c. 9, is still in force. Bill of Itights, art. 5; Alexander's Brit. St. p.
049. In MISSISSIPPI, only notes for the payment of a sum of money are
properly negotiable, notes payable in "any other thing" being merely assign-
able subject to equities. Ann. Code, §§ 3502, 3503. In MISSOURI, only notes
"for the payment of money" are clothed by statute with the negotiable
character of inland bills of exchange. Rev. St. § 733. In NEBRASKA, all
negotiable instruments must be "for any sum or sums of money certain."
Comp. St. § 33G0. In NEVADA, negotiable notes must be for the payment of
a "sum of money therein mentioned." 1 Comp. Laws 1S73, c. 5, § 9; P. L.
1861, p. 4. So, in NEW JERSEY. Gen. St. 2604. In NORTH CAROLINA,
negotiable instruments must be for money. Code, § 41. So, in OHIO. Rev.
St. § 3171. So, in OREGON. Hill's Ann. Laws, § 3188. In PENNSYLVANIA,
bills of exchange, drafts, notes, checks, etc., drawn or indorsed in that state
"payable in any other state, territory, country or place," may be payable "in
current funds" or in money with rate of exchange or like qualification super-
added. Purd. Dig. p. 1732, § 2; P. L. 1849, p. 427, § 11. In RHODE
ISLAND, negotiable notes must be for the payment of mouoy only. Gen. Laws,
c. 166, § 7. So, in SOUTH CAROLINA. Rev. St. § 1393. So, in TEN-

130 Bainbridge v. Owen, 2 J. J. Marsh (Ky.) 463. So, a bill payable in
"current funds" has been held to be payable in current money, and nego-
tiable. Laird v. State, 61 Md. 309. If payable in "current money," the amount
of recovery will be the specie value of such currency as it would be most for
the promisor's interest to have paid. Miller v. McKinney, 5 Lea (Teun.) 93.


current money of Kentucky"; ^*° ''in lawful current money of Penn-
sylvania"; ^*^ "in good current money of this state"; ^*- in "lawful
money"; ^" "in York state bills or specie"; ^^* "in exchange"; ^*^ "in
good solvent cash notes"; ^*® but not a receipt for an amount "in
checks," payable generally.^*^

On the other hand, the following bills and notes have been held
not payable in money and not negotiable, viz.: "In Now York
funds"; ^*^ "in Tennessee money"; ^*" "in current Mississippi bank

NESSEE. Ann. Code, § SoOo. And the same is true of every negotiable
sealed bill, bond, or note. Id. § 3500. But bills or notes for specific articles
are only assignable. Id. In VERMONT, negotiable bills and notes must be for
the payment of money. St. § 2306. So. in WEST VIRGINIA, negotiable not"s
and checks. Code, c. 99, § 7. So, in WISCONSIN, all negotiable not s. Ann.
St. § 1G75. By the negotiable instruments law of 1S97, such instruments m ist
be drawn "to pay a sum certain in money" in COLORADO, CONNECTI-
WASHINGTON (Codes & St. § 3<350).

14^ McChord v. Ford, 3 T. B. Mon. 166, there being no current money in
Kentucky at that time except specie.

1-11 Meaning congressional legal tender, Wharton v. Morris, 1 Dall. 125.

142 Graham v. Adams. 5 Ark. 201.

143 Dorrance v. Stewart, 1 Yeates (Pa.) 349, the note being made in Con-
necticut, and intended to mean lawful money of Connecticut.

144 Keith v. Jones. 9 Johns. (N. Y'.) 120. See New York Statutes; 1 Rev. St,

145 Bradley v. Lill, 4 Biss. 473, Fed. Cas. No. 1,7S3, overruling Lowe v.
Bliss, 24 111. 168. But a note "payable by New York or Chicago exchange" is
payable in bills, and has been held not to be negotiable. First Nat. Bank v.
Slette, 67 Minn. 425, 69 N. W. 114S.

146 Baker v. Todd, G Tex. 273; Smith v. Falwell. 21 Tex. 466, distinguish-
ing such notes from a promise to pay in cash notes. But in Lawrence v.
Dougherty, 5 Yerg. (Tenn.) 435, a note for $500 "which may be discharged in
merchantable cotton" was held to be the same thing as a note payable in
cotton, and therefore not negotiable. Notes payable "in good solvent cash
notes" are said to constitute a "money demand" on failure to deliver the
notes. Grant v. Burleson, 38 Tex. 214. But see, contra. Ward v. Lattimer,
2 Tex. 245. Williams v. Sims, 22 Ala. 512; Hopkins v. Seymour, 10 Tex. 202.

147 First Nat. Bank v. Greenville Nat. Bank, 84 Tex. 40, 19 S. W. 334.

148 Hasbrook v. Palmer. 2 McLean, 10, Fed. Cas. No. 6,188.

149 Meaning Tennessee bank notes, Taylor v. Noblett, 4 Heisk. (Tenn.) 491.
But see Searcy v. Vance, Mart. & Y. (Tenn.) 225, to the effect that such ex-
pression is equivalent to money, and makes a negotiable note. So, as to
"Arkansas money." Wilburn v. Greer, 6 Ark. 255.

V.1 RAND.C.P.— 10 (145)


money"; ^^° "in Tennessee or Alabama money or its equivalent"; ^°^
''in Arkansas money of the Fa3-etteville Branch"; ^^^ "in Canada
money," the note being made in the United States; ^''^ in Brandon
money"; ^^* in "foreign bills"; ^^^ in "paper medium"; ^°° "in East
India bonds"; ^^^ in United States bonds; ^^® in Confederate bonds
(illegal and void).^^'' It is said, however, that a purchase-money
note for land, payable "in Mississippi certificates of indebtedness,"
is so far a note for money as to be secured by a vendor's lien.^""

A note payable in money will not lose its negotiability by reason
of an option contained in it for payment in United States bonds. ^*'
But a note payable "in bank stock or lawful money of the United
States" is not a negotiable note for the payment of money.^®^ Where
the means of payment provided for are not money, it follows that
the damages recoverable are not the amount named, but the value of
the medium named in money.^^'

150 That is, Mississippi bank notes. Hopson v. Fountain, 5 Humph. (Tenn.)

151 Chevallier v. Buford, 1 Tex. 503.

152 Hawkins v. Watkins, 5 Ark. 481.

153 Thompson v. Sloan, 23 Wend. (N. Y.) 71. This is the case also of a note
mado in Canada, and payable "in Canada bills," although provincial notes
were authorized and made a legal tender by statute of 29 & 30 Vict. c. 10.
Oray v. Worden, 29 U. C. Q. B. 535.

154 Gordon v. Parker. 2 Smedes & M. (Miss.) 495.

155 Meaning bills of country banks. Jones v. Fales, 4 Mass. 245.

156 Lange v. Kohne, 1 McCord (S. C.) 115.
»57 Byles, Bills, 94; Bull, N. P. 272.

168 Easton v. Hyde, 13 Minn. 90 (Gil. 83); Blouin v. Liquidators of Hart, 30
La. Ann. 714.

159 Prigeon v. Smith, 31 Tex. 171.

160 Deason v. Taylor, 53 Miss. 697. On the other hand, a promise in writing
to pay "county scrip" has been held to be an agreement, and not a note. Jones
V. State, 40 Ark. 344.

161 Dinsmore v. Duncan, 57 N. Y. 573. But such quality is lost by the
holder's indorsing his option to take bonds in payment. Id.

162 Alexander v. Oaks, 19 N. C. 513. See 1 Rev. St. N. C. c. 13, § 3. So,
a note containing an option to pay in money or property is not negotiable.
Taylor v. Tompkins, 1 White & W. Civ. Cas. Ct. App. § 1050. In such notes
the election belongs to the debtor, and the creditor can only demand money
on the debtor's failure to exercise his option. Nipp v. Diskey, 81 Ind. 214.

163 Hopson V. Fountain, 5 Humph. (Tenn.) 140; Chevallier v. Buford, 1 Tex.
503; Gordon v. Parker, 2 Smedes & M. (Miss.) 495.



It is believed tliat tlie rule requiring commercial paper to be pay-
able in money only, except so far as it has been changed by a few
statutes in the United States, is a universal one. It is implied in
the definitions and other provisions of nearly every foreign com-
mercial code, and assumed without discussion by French and Ger-
man writers on commercial law.^*^*

Payable "in Specie"— "Gold."

§ 97. A bill of exchange or promissory note payable "in gold"
or "in specie" is for the payment of money, and not for bullion or
merchandise.^ ^^ And therefore, as such, its negotiability has passed
unquestioned. In like manner a note payable "in specie or its equiv-
alent" is a note for money, on which an action of debt, not covenant,
will lie.^^° This view is, however, opposed to that of an earlier case
in Texas, where a note payable "in lawful funds of the United States,
or its equivalent," was held to be a contract for coin, nounegotiable.
and only assignable in equity.^^^

164 In ITALY, notes may be made to order for payment in produce, subject
to the same regulations as notes payable in money. Code Com. ai'ts. 275, 276.
But such notes or bills must be payable at a time fixed. Article 278. In
MEXICO (Code Com. art. 223) bills of exchange must be for the payment of an
amount particularly specified "in actual and current money."

16 5 Chrysler v. Renois, 43 N. Y. 209, "in gold dollars"; Wood v. Bul^ns, 6
Allen (Mass.) 51G; Strickland v. Holbrooke, 75 Cal. 2G8, 17 Pac. 204, "in United
States gold coin." So, too, a promise to pay "one thousand Mexican silver
dollars." Hogue v. Williamson, 85 Tex. 553, 22 S. W. 580.

166 Rhyne v. Wacaser, G3 N. C. 30. And it has been held that a note
payable "in gold or its equivalent in notes" may be satisfied by payment of
the sum named in United States legal tender notes. Killough v. Alford, 32
Tex. 457, and that in such case judgment should be rendered for gold or its
equivalent in United States legal tender notes, and that a judgment for the
amount in gold is erroneous. Wells, Fargo & Co. v. Van Sickle, 6 Nev. 45.
But see Holt v. Given, 43 Ala. G12, where it was held that payment of such
note could only be made in legal tender notes of equivalent value.

167 Ogderi V. Slade, 1 Tex. 13, Lipscomb, J., saying: "By 'equivalent' the
parties must have meant such paper currency as passed at par with gold.
This alternative of an equivalent would perhaps restrain the negotiability and
destroy the mercantile character of the paper, so that It would not pass by
delivery, and the holder might not maintain a suit iu his own name on it at
common law."



Legal Tender Act and Decisions.

§ 98. The United States legal tender act of 1862 provides that the
United States notes issued under that act "shall be lawful money and a
legal tender in payment of all debts, public and private, within the
United States, except for duties on imports and interest on the pub-
lic debt." ^^^ This act led to many conflicting decisions, the princi-
pal of which are noted in the following sections. In 18G5 it was
held to be unconstitutional by the court of errors of the state of Ken-
tucky, so far as it affected contracts made prior to the passage of
tlip act.^®° This decision was affirmed by the supreme court of the
United States, in December, 1869, and judgment to that effect an-
nounced by the court in the following February.^'^ Fifteen months
later it was expressly overruled by the same court, and the legal
tender act has since that time been generally held by the courts to be
applicable to contracts made before its passage.^^^

168 Rev. St. U. S. § 35SS. This was afterwards extended to the greenback
issues of 1863, 1864, and 1872, the latter, howeA^er, not extending to the
redemption of banlv notes "calculated and intended to circulate as money."
Id. § 3590.

169 Griswold v. Hepburn, 2 Duv. (Ky.) 20. This case was upon a promissory
note for "eleven thousand dollars" made in 18G0, and falling due February
20, 1862, five days before the passage of the Legal Tender Act. The judg-
ment was for recovery in gold or its equivalent value.

170 Hepburn v. Griswold, 8 Wall. 603. As to the argument urging the neces-
sity of the Legal Tender Act as incident to the power to make war, Chief
Justice Chase says (page 625): "We are obliged to conclude that an act
making mere promises to pay dollars a legal tender in payment of debts pre-
viously contracted is not a means appropriate, plainly adapted, really calcu-
lated to carry into effect any express power vested in congress, that such an
act is inconsistent with the spirit of the constitution, and that it is prohibited
by the constitution." Mr. Justice Miller, dissenting from this, says (page
639): "If the act to be considered is in any sense essential to the execution
of an acknowledged power, the degree of that necessity is for the legislature,
and not for the court, to determine." The judgment was rendered by a
vote of five judges for affirmance (Chase, C. J., Nelson, Clifford, Grier, and
Field, JJ.), three judges dissenting (Miller, Swayue, and Davis, JJ.).

171 Legal Tender Cases, 12 Wall. 457. This case overruled Hepburn v.
Griswold, by a similar vote of five judges (Miller, Swayne, Davis, Strong,
and Bradley, JJ.), four judges dissenting (Chase, C. J., and Nelson, Clifford,
and Field, JJ,). The personnel of the court had been changed In the mean-



And it has been held that a note payable "in gold" may be sat-
isfied under the legal tender act by payment in legal tender notes.^^'

time by the resignation of Mr. Justice Grier and the appointment of Messrs.
Justices Strong and Bradley. For a protest against tliis extraordinary action
of the court and an account of the circumstances by which it was brought
about, the reader is referred to the dissenting opinions of Chief Justice Chase
(page 572) and Mr. Justice Clifford (page GU4). Mr. Justice Bradley, in his
opinion (page 567), says: "I do not say that it is a war power, or that it is
only to be called into exercise in time of war." And Mr. Justice Strong saya
of the obligation of the contract (page 548): "It was not a duty to pay
gold or silver or the kind of money recognized by law at the time when the
contract was made, nor was it a duty to pay money of equal intrinsic value
in the market. The expectation of the creditor and the anticipation of the
debtor may have been that the contract would be discharged by the pay-
ment of coined metals, but neither the expectation of one party to the contract
respecting its fruits, nor the anticipation of the other, constitutes its obli-
gation. * * * The obligation of a contract to pay money is to pay that
which the law shall recognize as money when the payment is to be made."
In the Hepburn Case that would have been coin. This principle has since
been extended by the United States supreme court, in Juilliard v. Greenman,
110 U. S. 449, 4 Sup. Ct. 122, to greenbacks reissued under the act of 1878
(Field, J., dissenting). The opinion of the court, read by Mr. Justice Gray,
puts the act upon a peace footing, as follows: "Congress, as a legislature
of a sovereign nation, being expressly empowered by the constitution 'to
lay and collect taxes, to pay the debts and provide for the common defense
and general welfare of the United States,' and 'to borrow money on the
credit of the United States,' and 'to coin money and regulate the value thereof
and of foreign coin'; and being clearly authorized and as incidental to the
exercise of those great powers to emit bills of credit, to charter national banks,
and to provide a national currency for the whole people in the form of coin,
treasury notes and national bank bills; and the power to make the notes of
the government a legal tender in payment of private debts being one of the
powers belonging to sovereignty in other civilized nations, and not expressly
withheld from congress by the constitution,— we are irresistibly impelled to
the conclusion that the impressing upon the treasury notes of the United
States the quality of being a legal tender in payment of private debts is an
appropriate means, conducive and plainly adapted to the execution of the
undoubted powers of congress, consistent with the letter and spirit of the
constitution, and therefore, within the meaning of that instrument, necessary
and proper for carrying into execution the powers vested by this constitution
in the government of the United States."

iT2Buchegger v. Shultz, 13 Mich. 420; Jump v. Peltier, IS La. Ann. 193;
Riley v. Sharp, 1 Bush (Ky.) 348; Gist v. Alexander, 15 Rich. Law (S. G.)
50. See, too, ShoUenberger v. Brinton, 52 Pa. St. 9, virtually ove^rruled in



And, where made in 1S58 '*to be paid in gold or silver," judgment
for the amount in ''dollars'' was held to be correct.^''' Indeed, the
addition of the words "in gold'' was held to be an immaterial alter-
ation in 1800. when there was no other means of payment.^^* So,
too. United States legal tenders have been held sufficient payment
of a note "payable in specie." ^^^ But in a later case in Vermont
it was held that the holder was entitled to an amount of currency
equivalent in value to the amount in specie at the time of render-
ing judgment. ^^° And in the United States supreme court it was
held, at the same term at which the legal tender cases were decided,
that a note "payable in specie" could only be satisfied by payment
in coined dollars.^" And this may now be regarded as the rule re-
garding bills, notes, and other contracts payable either "in gold" or
"in specie." ^'^

The rule is still clearer that judgment must be for coin on all
notes and bills payable "in coin"; ^^^ or "in gold and silver coin"; ^»*

McCalla v. Ely, G4 Pa. St. 254. But it was held in Glass v. Pullen, 6 Bush
(Ky.) 346, that a judgment on such note should be for gold or its equivalent
in legal tender notes, and that such a note given for a loan of equal amount
in legal tender notes was a usurious contract; and in Hittson v. Davenport.
4 Colo. 169, that a payment in currency on such note should only be credited
to the amount of its value in gold, the note being for so many "dollars gold
* * * in gold." A municipal bond reciting an indebtedness "in gold coin,"
"which sum they bind themselves to pay," is a promise to pay money or legal
tender. Woodruff v. State of Mississippi, 102 U. S. 291, 16 Sup. Ct. 820.

173 Johnson's Adm'r t. Vickers, 1 Duv. (Ky.) 206.

174 Bridges v. Winters, 42 Miss. 135.

175 Wood v. Bullens, 6 Allen (Mass.) 516. So, Flournoy v. Ilealy, 31 Tex.
590, where the note was for a specified sum "in specie" or a larger sum "in
United States currency," and the judgment was rendered for the smaller sum.

■i^s Townsend v. .leunison, 44 Vt. 315. But see Flournoy v. Healy, 31 Tex.

177 Trebilcock v. Wilson, 12 Wall. 087, Miller and Bradley, JJ., dissenting.

17 8 And, where a note is payable "in gold or its equivalent in currency," the
recovery will be an amount in currency equal in value to the amount named
in gold. Dunn v. Barnes, 73 N. C. 273. And, as to the enforcement of such
contracts, see Burnett v. Stearns, 33 Cal. 408; Bridges v. Reynolds, 40 Te.x. 204.

170 Toett V. Stearns, 31 Cal. 78; Phillips v. Dugan, 21 Ohio St. 406; Smith
V. Wood, 37 Tex. 616; Bowen v. Darby, 14 Fla. 202; Churchman v. Martin,

180 See note 180 on following paga.


or in "gold dollars"; ^^^ or "lawful silver monej"; ^^^ or in "English
golden guineas and other gold and silver at the present established
weight and rate'';^^^ or "in gold coin of the United States of the
present standard of weight and fineness, notwithstanding any law
which now may or hereafter shall make anything else a tender in
payment of debts." ^^*

Payable in "Current Funds" — "Currency.'*

§ 99. It appears to be established in some states that a bill or note
payable in "current funds" is payable in money, and therefore ne-
gotiable.^ ^° So, too, a note payable "in current funds of the state
of Ohio";^^^ or "in funds current in the city of New York";^*^ or
a certificate of deposit for flOO "in funds * * * to be paid in
like funds." ^*® In other states the contrary has been held as to

54 Ind. 380. Altliougli it was held that judgment on such a note should be
for "dollars," not for coin, in Preston v. Breedlove, 36 Tex. 96. So, on a note
payable "in gold or its equivalent," the premium on gold existing at the
maturity of the note, and not at the time of judgment, will not be taken into
account. Atkinson v. Lanier, 69 Ga. 460.

180 Bronson v. Rodes, 7 Wall. 229, approved in Trebilcock v. Wilson, 12
Wall. 6S7, Miller, J., dissenting in both cases. So, too, if payable "in gold
or silver coin." Smith v. McKinney, 22 Ohio St. 200. But see, contra, Hast-
ings v. Johnson, 2 Nev. 190; Glover v. Robbins, 49 Ala. 220.

181 Lafitte v. Rivera, 23 La. Ann. 32. This decision relied on the authority
of Hepburn v. Griswold, 8 Wall. 603, since overruled in the Legal Tender
Cases, 12 Wall. 457.

182 McCalla v. Ely, 64 Pa. St. 2o4, overruling Shollenberger v. Brinton, 52
Pa. St. 9.

183 Butler V. Horwitz, 7 Wall. 258,

184 Button V. Pailaret, 52 Pa. St. 109.

185 Bull V. Bank, 123 U. S. 105, 8 Sup. Ct. 62; American Emigrant Co. v.
Clark, 47 Iowa, 671. To the same effect, see Wood v. Price, 46 111. 435;
Galena Ins. Co. v. Kupfer, 28 111. 332; Kupfer v. Marc, Id. 388. affirmed as
Marc V. Kupfer, 34 111. 2S6; Williams v. Amis, 30 Tex. 37. See, too. Blood
V. Northup, 1 Kan. 28.

186 White V. Richmond, 16 Ohio, 5.

187 Lacy V. Holbrook, 4 Ala. 88.

188 Swift V. Whitney, 20 111. 144.



instruments payable *'in current funds"; ^^^ "in current funds at
Pittsburgh"; i»° "in New Yorl^ funds or their equivalent."^"

The same difference prevails in the decisions as to bills and notes
payable "in currency." Such instruments are held to be negotiable
in many states.^ ^^ gQ^ ^qq^ ^ ^^^g payable in "greenback curren-
^y>>.i93 Qj. jjj "paper currency" (meaning legal tender notes); ^°* or
"in currency at its specie value"; ^^^ or "in the common currency
of the country, — that which will pay taxes"; ^^® or "in currency at
the present rates, 148 to 100, or in whatever good currency may be
used at the time the note falls due," such note being payable in
United States currency, although of improved value.^®^ In North
Carolina, however, "undepreciated currency" was held not to mean
coin, but "ordinary commercial and business currency." ^^^

The following expressions also have been held to mean cash or
money, the instrument payable in such manner being negotiable,

188 Piatt V. Bank, 17 Wis, 222; Lindsey v. McClelland, 18 Wis. 481; John-
son V. Henderson, 76 N. C. 227; Haddock v. Woods, 46 Iowa, 433; National
State Bank of Lafayette v. Ringel, 51 Ind. 393; Conwell v. Pumphrey, 9 Ind.
135; Texas Land & Cattle Co. v. Carroll, 63 Tex. 52.

190 Wright V. Hart, 44 Pa. St. 454.

181 Hasbrook v. Palmer, 2 McLean, 10, Fed. Cas. No. 6.188.

192 Howe V. Hartness, 11 Ohio St. 449; Fry v. Dudley. 20 La. Ann. 368;
Butler V. Paine, 8 Minn. 324 (Gil. 284); Klauber v. Biggerstaff, 47 Wis. 551,
3 N. W. 357; Id., 9 Cent. Law J. 488 (collecting and reviewing a great number
of American cases); Phelps v. Town, 14 Mich. 374, Christiancy, J., defining
currency to be "money current by law or paper equivalent in value circulating
in the community at par." In Swift v. Whitney, 20 111. 144, Walker, J.,
says: "By the term 'currency' is understood bank bills or other paper money
Issued by authority, which pass as and for coin. * * * It would seem that
current bills or currency are of the value of cash, and exclude the idea of
depreciated paper money." See, too, the remarks of Field, J., in Trebilcock
V. Wilson, 12 Wall. 095; also, Paup v. Drew, 10 How. 218.

193 Burton v. Brooks, 25 Ark. 215, national bank notes not being included in
Buch designation.

194 Frank v. Wessels, 64 N. Y. 155.

105 Caldwell v. Craig, 22 Grat. (Va.) 340, such note being held to be payable
in specie.

i»s Johnson v. Miller, 76 N. C. 439, United States legal tender notes being
meant, at least prima facie.

19T Echols v. G rattan, 42 Ga. 547.

i»8 Blackburn v. Brooks, 65 N. C. 413.


viz.: "New York state currency"; ^®^ "currency of the state of Mis-
sissippi"; ^o" "Kentucky currency"; ^"^ "currency of Missouri"; ^°^
"currency of Zanesville"; ^"^ "Canada currency"; ^*^* "current mon-
ey of the state of Alabama." ^°^

On the other hand, the following have been held not to be ne-

Online LibraryJoseph F. (Joseph Fitz) RandolphA treatise on the law of commercial paper; containing a full statement of existing American and foreign statutes, together with the text of the Commercial codes of Great Britain, France, Germany and Spain (Volume 1) → online text (page 46 of 125)