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24 Tul. L. Rev. 263 (1949-1950)
Reviews

handle is hein.journals/tulr24 and id is 283 raw text is: REVIEWS he owes such visitor the duty of reasonable care. Powell v. Great Lakes Transit Co., 152 Minn. 90, 188 N. W. 61 (1922) (good will) ; Fournier v. New York, N. H. & H. R. R., supra (comfort to pas- sengers) ; cf. Cherokee Packet Co. v. Hilson, 95 Tenn. 1, 31 S. W. 737 (1895) ; of. Hutchins v. Penebscot Bay & River Co., 110 Me. 269, 86 Atl. 250 (1913). An extreme position has been taken by one court which declared that the visitor's motive does not affect his rights, because he was owed the duty of reasonable care if per- mitted upon the vessel. See The Montrose, 179 Fed. 1000, 1001 (1910). The particular problem raised by the instant case has not ap- peared in Louisiana jurisprudence. In an early case, a slave boarded defendant's vessel to sell milk to the steward for the use of the cabin, and was drowned due to a defective gangway from which he fell, the court stating that the defendant's liability extended only to members of the crew, laborers on the ship, and passengers. Dowty v. Templeton, 9 La. Ann. 549 (1854). Should this old rule still be applied it would seem that Louisiana would be in accord with the instant case. However, Louisiana courts have granted recovery to a plaintiff who came upon defendant railroad's premises to mail a letter in its mail car, the court holding that a government contract to carry mail was sufficiently advantageous to accord the plaintiff the status of invitee. Bell v. Houston & S. R. R., 132 La. 88, 60 So. 1029 (1913). It is submitted that courts in applying the test of mutuality of interest to social visitors on board vessels, may wish to give consideration to the ultimate economic benefit to be derived by the owner or occupier as well as to the customs prevailing in the particular port. STANLEY MCDERMOTT, JR. REVIEWS CIERTOS PRINCIPIOS CARACTERISTICOS DEL COMMON LAW. By Phanor J. Eder. La Habana, Cuba: Academia Interamericana de Derecho Comparado e Internacional. 1948. Pp. 198. This book reproduces a series of lectures delivered by the author at the Interamerican Academy of National and Compartive Law in Havana, Cuba, during the year 1947. The lectures were intended for lawyers practicing in Latin American countries: they pre-sup- pose, therefore, a working knowledge on the part of the reader of the basic problems of the civil law. Their main purpose is to point 1949]