The Constitution of the United States1 gives to Congress the power to establish "uniform laws on the subject of bankruptcies throughout the United States." Under this grant of power Congress has enacted four distinct bankrupt acts which have been in force altogether only thirty-eight years since the foundation of our present government.2 The present bankrupt act took effect July 1, 1898, and was amended February 5, 1903, June 25, 1910, and March 2, 1917.

1 For English legislation on insolvent traders and other debtors and on bankruptcy, see 34 & 35 Hen. VIII, c. 4; 13 Eliz., c. 7; 1 Jac. I, c. 15; 21 Jac I, c. 10; 4 Anne, c. 17; 10 Anne, c. 15; 6 Geo. IV, c. 16; 24 & 25 Vict., c. 134; 32 & 33 Vict, c. 71; 46 & 47 Vict., c. 52; 50 & 51 Vict., c. 66; 52 & 53 Vict, c. 63; Sec. 38; 3 & 4 Geo. V, c. 34; 4 & 5 Geo. V, c. 47; 4 & 5 Geo. V, c 59.

On the general question of bankruptcy, see The Early History of English Bankruptcy, by Louis E. Levinthal, 67 University of Pennsylvania Law Review, 1; English and Scottish Bankruptcies, by John Burns, 29 Law Quarterly Review, 460; Bank-ruptcy a Commercial Regulation, by James M. Olmstead, 15 Harvard Law Review, 829; Ancillary Receiverships in Bankruptcy, by Lee Max Friedman, 18 Harvard Law Review, 519; Debtor's

Interference in the Election of a Trustee in Bankruptcy, by Lee Max Friedman, 19 Harvard Law Review, 106; Distribution of Assets of Bankrupt Partnerships and Partners, by William J. Shroder, 18 Harvard Law Review, 495, and Unrecorded Conditional Sales in Bankruptcy, by Samuel Williston, 24 Harvard Law Review, 620.

1 Art. I, 8, par. 4.

2 In Hanover National Bank v. Moyses, 186 U. S. 181, 46 L. ed. 1113, Fuller, C. J., gave the following list of federal bankrupt acts as in force prior to the act of 1898:

Act of 1800, 2 Stat. 19, c. 19. Repealed 1803, 2 Stat. 248, c. 6.

Act of 1841, 5 Stat. 440, c. 9. Repealed 1843, 5 Stat. 614, c. 842.

Act of 1867, 14 Stat 517, c. 176. Repealed 1878, 20 Stat. 99, c. 160.

The Federal Bankrupt Act of 1898 is constitutional.3 Power to make laws on the subject of bankruptcies confers power to provide for voluntary bankruptcy, as well as involuntary bankruptcy; and the fact that the Bankrupt Act of 1898 provides for voluntary bankruptcy. without notice to the creditors of the filing of such petition, and that it does not require personal service of notice of the hearing of the debtor's application for his discharge, does not render it unconstitutional.4