90. In England a barrister cannot sue upon a contract for compensation for his services, but this disability does not exist in the United States.

In England, a barrister cannot sue for fees due him for services rendered in the ordinary course of his professional duties, either upon an implied or an express contract. Formerly a physician was so far in the same position as a barrister that, until the law was changed by statute, the rendition of services on request raised no implied promise to payfor them, though the patient might bind himself by express contract. But these disabilities are not to any extent recognized in this country.32 There are, indeed, in most, if not all, the states, statutes prescribing certain requisites to entitle a physician, attorney, and certain other professional men to practice, such as the taking out of a license; and, until he has complied with the statute, he has no right to practice, and contracts made with him for professional services are void. This, however, is properly for treatment later.33

26 Kynnaird v. Leslie, L. R. 1 C. P. 389, 12 Jur. N. S. 4CS. 35 L. J. C. P. 22G, 14 L. T. Rep. N. S. 756, 14 Wkly. Rep. 761. And see Avery v. Everett, 110 X. Y..317, 18 N. E. 148, 1 L. R. A. 264, 6 Am. St. Rep. 36S. See "Convicts," Dec. Dig. (Key-No.) § 4; Cent. Dig. § 3.

2754 Geo. Ill, c. 45; 33 & 34 Vict, c. 23. See Avery v. Everett, supra. See "Convicts," Dec. Dig. (Key-No.) §§ 3, 4; Cent. Dig. §§ 2, 3, 8.

28piatuer v. Sherwood, 6 Johns. Ch. (N. Y.) 118; Willingham v. King, 23 Fla. 478, 2 South. 851; In re Estate of Nerac, 35 Cal. 392, 95 Am. Dec. I11. And see Dade Coal Co. v. Haslett, S3 Ga. 549, 10 S. E. 435. See "Convicts," Dec. Dig. (Key-No.) § 4; Cent. Dig. § 3.

29 Avery v. Everett, supra; Smith v. Becker, 62 Kan. 541, 64 Pac. 70, 53 L. R. A. 141; In re Estate of Nerac, 35 Cal. 392, 95 Am. Dec. 111. See "Convicts," Dec. big. (Key-No.) § 4; Cent. Dig. § 3.

30 Smith v. Becker, supra; Williams v. Shackelford, 97 Mo. 322, 11 S. W. 222. See "Convicts," Dec. Dig. (Key-No.) § 4; Cent. Dig. § 3.

31 In re Deming, 10 Johns. (N. Y.) 232. See "Convicts," Dec. Dig. (Key-No.) § 4; Cent. Dig. § 3.