As we have seen, a promise to pay a public officer for performing duties which he is required by law to perform without such compensation, or to pay him more than the fees fixed by law, is void for lature may provide for sale of an office. Town of Thetford v. Hubbard. 22 Vt 440. See "Contracts," Dec. Dig. (Key-No.) § 124; Cent. Dig. §§ 516-585.

42 Blatchford v. Preston, 8 Term R. 89; Card v. Hope, 2 Barn. & C. 661. See "Contracts," Dec. Dig. (Key-No.) § 124; Cent. Dig. §§ 516-585.

43 Stroud v. Smith, 4 Houst. (Del.) 448. See "Contracts" Dec. Dig. (Key-No.) § 12k; Cent. Dig. §§ 576-585.

44 Gray v. Hook, 4 N. Y. 449; Law v. Law, 3 P. Wms. 391; Meguire v. Corwine, 101 U. S. Ill, 25 L. Ed. 899; Nichols v. Mudgett, 32 Vt 546; Martin v. Wade, 37 Cal. 168; Hunter v. Nolf, 71 Pa. 282; Morse v. Ryan, 26 Wis. 356; Harris v. Chamberlain, 126 Mich. 280, 85 N. W. 728; Eversole v. Holli-day, 131 Ky. 202, 114 S. W. 1195. A contract by the heir not to object to the public administrator acting as administrator of the estate is void as trafficking in the office. In re Irwin's Estate, 123 Mo. App. 508, 100 S. W. 565. See "Contracts," Dec. Dig. (Key-No.) § 124; Cent. Dig. §§ 516-585.

45 Hartwell v. Hartwell, 4 Ves. 811; Edwards v. Randle, 63 Ark. 318, 38 S. W. 343, 36 L. R. A. 174, 58 Am. St Rep. 108. See "Contracts," Dec. Dig. (Key-No.) § 124; Cent. Dig. §§ 516-585.

46Eddy v. Capron, 4 R. I. 394, 67 Am. Dec. 541; Meacham v. Dow, 32 Vt 721; Basket v. Moss, 115 N. C. 448, 20 S. E. 733, 48 L. R. A. 842, 44 Am. St Rep. 463. And see Forbes v. McDonald, 54 Cal. 98. See "Contracts" Dec. Dig. (Key-No.) § 124; Cent. Dig. §§ 516-585.

47 Greenh. Pub. Pol. rule 293, p. 349. An agreement by which one party stipulates to pay the other a proportion of the fees and emoluments of a public office which he is seeking, in consideration that the other will aid him in obtaining it is void. Gray v. Hook, 4 N. Y. 449. And see Deyoe v. Wood-worth, 144 N. Y. 448, 39 N. E. 375. See "Contracts," Dec. Dig. (Key-No.) i 125; Cent. Dig. §§ 588-585.

48 Engle v. Chipman, 51 Mich. 524, 16 N. W. 8S6; Schloss v. Hewlett, 81 Ala. 266, 1 South. 263. See "Contracts," Dec. Dig. (Key-No.) § 125; Cent. Dig. §§ 583-585.

49 Price v. Caperton, 1 Duv. (Ky.) 207. See "Contracts," Dec, Dig. (Key-No.) § 125; Cent. Dig. §§ 583-585.

want of consideration.50 Such contracts are also illegal as being contrary to public policy.51 "The rewards of officers," it has been said, "are established by law. Their services are to be performed for those legal rewards; and other private rewards for acts which are required from them * * * must be regarded as corrupt and illegal exactions." 52 To recognize as valid contracts for additional compensation would tend to cause officers to neglect their duties unless promised such additional compensation, and would thus tend to make bribery the only means by which the laws could be enforced.53 The rule does not apply so as to prevent an officer from recovering on a promise to pay him for doing more than he is required by law to do."

It has also been held that an agreement by a public officer, before performance of services, to accept less than the fees fixed by law, is against public policy.55

50 Ante, p. 157.

51 Weaver v. Whitney, 1 Hopk. Ch. (N. Y.) 13; Preston v. Bacon, 4 Conn. 471; Neustadt v. Hall, 58 I11. 172; Trundle's Adm'r v. Riley, 17 B. Mon. (Ky.) 396; Gilmore v. Lewis, 12 Ohio, 281; Brown v. Bank, 137 Ind. 655, 37 N. E. 158, 24 L. R. A. 206; Adams Co. v. Hunter, 78 Iowa, 328, 43 N. W. 208, 6 L. R. A. 615; Foley v. Platt, 105 Mich. 635, 63 N. W. 520; ante, p. 157, and eases there cited. Bond of indemnity given a sheriff to induce him to do what he was required to do without it Mitchell v. Vance, 5 T. B. Mon. (Ky.) 528, 17 Am. Dec. 96. Bond indemnifying officer against loss for omitting to execute process. Harrington's Adm'r v. Crawford, 136 Mo. 467, 38 S. W. 80, 35 L. R. A. 477, 58 Am. St. Rep. 653. A public officer is not entitled to reward offered for the arrest which it was his duty to make without pay. Smith v. Whildin, 10 Pa. 39, 49 Am. Dec. 572; Gilmore v. Lewis, 12 Ohio, 281; Pool v. City of Boston, 5 Cush. (Mass.) 219; Stamper v. Temple, 6 Humph. (Tenn.) 113, 44 Am. Dec. 296; Davies v. Burns, 5 Allen (Mass.) 349. See "Contracts," Dec. Dig. (Key-No.) § 125; Cent. Dig. §§ 5SS-5S5.

52 Weaver v. Whitney, 1 Hopk. Ch. (N. Y.) 13. See "Contracts," Dec. Dig. (Key-No.) § 125; Cent. Dig. §§ 583-585.

53 Dull v. Mammoth Min. Co., 28 Utah, 467, 79 Pac. 1050. See "Contracts," Dec. Dig. (Key-No.) § 125; Cent. Dig. §§ 583-585.

54 Trundle v. Riley, 17 B. Mon. (Ky.) 396; McCandless v. Steel Co., 152 Pa. 139, 25 Atl. 579; Carroll v. Tyler, 2 Har. & G. (Md.) 57. An officer may recover a reward offered for apprehension of a criminal, if it was no part of his duty to make the arrest Morrell v. Quarles, 35 Ala. 544; Evans v. Inhabitants of City of Trenton, 24 N. J. Law, 764. See "Contracts," Dec. Dig. (Key-No.) § 125; Cent. Dig. §§ 583-585.

55 Bodenhofer v. Hogan, 142 Iowa, 321, 120 N. W. 659, 134 Am. St Rep. 418, 19 Ann. Cas. 1073; Gallaher v. City of Lincoln, 63 Neb. 339, 88 N. W. 505; City of Pittsburg v. Goshorn, 230 Pa. 212, 79 Atl. 505; Hawkeye Ins. Co. v. Brainard, 72 Iowa, 130, 33 N. W. 603; Edgerly v. Hale, 71 N. H. 138, 51 Atl. 679 (sheriff's fee for service payable only if action successful). Contra, Bloom v. Hazzard, 104 Cal. 310, 37 Pac. 1037. Cf. Peters v. City of Davenport, 104 Iowa, 625. 74 N. W. 6, See "Contracts," Dec Dig. (Key-No.) § 125; Cent. Dig. §§ 583-585.

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