What are known as "lobbying contracts" also fall within this class of illegal agreements. Any agreement to render services in procuring legislative action, either by congress or by a state legislature or by a municipal council, by personal solicitation of the legislators or other objectionable means, is contrary to the plainest principles of public policy, and is void.90 "A contract for lobby services," it is said in a New York case, "for personal influence, for mere importunities to members of the legislature or other official body, for bribery or corruption, or for seducing or influencing them by any other arguments, persuasions, or inducements than as directly and legitimately bear upon the merits of the pending application, is illegal, and against public policy, and void;"61 and it has been held that a promise to pay a contingent fee on the passage of a bill is void, because such a fee is "a direct and strong incentive to the exertion of not merely personal, but sinister, influence upon the legislature." 62

60 TRIST v. CHILD, 21 Wall. 441, 22 L. Ed. 623, Throckmorton Cas. Contracts, 241; Spalding v. Ewing, 149 Pa. 375, 24 Atl. 219, 15 L. R. A. 727, 34 Am. St Rep. 608; Frost v. Belmont, 6 Allen (Mass.) 152; Rose v. Truax, 21 Barb. (N. T.) 361; Powers v. Skinner, 34 Vt. 274, 80 Am. Dec. 677; Mc-Bratney v. Chandler, 22 Kan. 692, 31 Am. Rep. 213; Cook v. Shipman, 24 I11. 614; Houlton v. Dunn, 60 Minn. 26, 61 N. W. 898. 30 L. R. A. 737, 51 Am. St. Rep. 493; Colusa County v. Welch, 122 Cal. 428, 55 Pac. 243; Hay-ward v. Manufacturing Co., 85 Fed. 4, 29 C. C. A. 438; Burke v. Wood (C. C.) 162 Fed. 533. "It is not necessary to adjudge that the parties stipulated for corrupt action, or that they intended that secret and improper resorts should be had. It is enough that the contract tends directly to those results. It furnishes a temptation to the plaintiff to resort to corrupt means or improper devices to influence legislative action. It tends to subject the legislature to influences destructive of its character, and fatal to public confidence in its action." Mills v. Mills, 40 N. Y. 543, 100 Am. Dec. 535. And see Veazey v. Allen, 173 N. Y. 359, 66 N. E. 103, 62 L. R. A. 3G2. See "Contracts," Dec. Dig. (Key-No.) § 126; Cent. Dig. §§ 586-593.

61 Brown v. Brown, 34 Barb. (N. Y.) 533. And see Sweeney v. McLeod, 15 Or. 330, 15 Pac 275. See "Contracts," Dec. Dig. (Key-No.) § 126; Cent. Dig. §§ 586-593.

62 Wood v. McCann, 6 Dana (Ky.) 366. And see Marshall v. Railroad Co., 16 How. 314, 14 L. Ed. 953; Coquillard's Adm'r v. Bearss, 21 Ind. 479, 83 Am. Dec. 362; Harris v. Roofs Ex'rs, 10 Barb. (N. Y.) 489; Weed v. Black, 2 MacArthur (9 D. C.) 268, 29 Am. Rep. 618; Chippewa Valley & S. Ry. Co. v. Railway Co., 75 Wis. 224, 44 N. W. 17, 6 L B. A, 601; Critch-field v. Paving Co., 174 I11. 466, 51 N. E. 552, 42 L. R. A. 347; Richardson v. Scotts Bluff County, 59 Neb. 400, 81 N. W. 309, 48 L. R. A. 294, SO Am. St. Rep. 682. But see, contra, Bryan v. Reynolds, 5 Wis. 200, 68 Am. Dec. 55; Workman v. Campbell, 46 Mo. 305; Burbridge v. Fackler, 2 MacArthur (9 D. C.) 407; Denison v. Crawford Co., 48 Iowa, 211; Bergen v. Frisbie, 125 Cal. 168, 57 Pac. 784. The legislature may determine what public policy requires or permits in prosecuting claims of the state against the United

The rule, however, does not apply to an agreement, for purely professional services, such as the drafting of a petition to set forth a claim for presentment to the legislature, attending the taking of testimony, collecting facts, preparing arguments, and submitting them orally or in writing to a committee or other proper authority, and other services of like character. They rest on the same principle of ethics as professional services rendered in a court of justice, and are no more objectionable.63