Special attention must be given to a note or bill indorsed after its maturity, in which case the paper becomes ordinary demand paper. If the note has not been presented for payment at maturity, the indorser upon it, except in exceptional cases, has been released. But if an indorser before maturity takes up and sells the note, after maturity he is liable to the holder upon his former indorsement as a guarantor.1 Or if the holder of the note who has extended it indorses to an indorsee without notice of the extension, no demand as to him is necessary;2 but the indorser after maturity, it has been held,

35 Jex v. Tureaud, 19 La. Ann. 64; Apperson v. Bynum, 5 Cold. 341.

36 See Sec. 268, post.

37 See Simonds v. Black River Ins. Co., Fed. Cas. No. 12,874; Windham Bank v. Norton, 22 Conn. 213; Scho-field v. Bayard, 3 Wend. 488; contra, Grant v. Long, 12 La. 402 (cases on other kinds of negotiable paper). Would this rule apply while the paper was being transmitted to an agent in order that the agent might make the demand? It should apply if the reasons of the rule are good.

38 See Sec. 251, ante, note 23, for other paper.

39 Durnford v. Johnson, 2 Mart (O. S.) 183.

40 Barker v. Parker, 6 Pick. 80. 41 McDonald v. Mosher, 23 I11 App. 206. 42Wilson v. Senier, 14 Wis. 380.

1 St John v. Roberts, 31 N. Y. 441; Coleman v. Dunlap, 18 S. C. 591.

2 Williams v. Probst, 10 Watts, 111; Ridgway v. Day, 13 Pa. 20a may show in. defense of his liability as to his immediate indorsee the non-performance by the indorsee of a special agreement made at the time of the indorsement.3 But gen-erally speaking, an indorser after maturity or dishonor of a note is treated as the indorser of a new note payable upon demand, and the indorser of a bill after maturity is treated as the drawer of a new bill payable upon demand.4 It makes little difference whether the indorser is treated as the indorser of a new note or the drawer of a new bill payable upon demand. In either case he is entitled to claim a demand for payment within a reasonable time, whether the maker was insolvent or not at the date of the indorsement, and without regard to the indorsees knowledge of the insolvency.5 Here again the cases vary widely in their application of the term " reasonable time." A delay of twenty-five days,6 or from April 19th to July 3d in the same year,7 or from July 30th to November 21st in the same year,8 or of ten months,9 or of twenty-four months,10 or of one year,11 or two years,12 has been considered unreasonable under varying circumstances, while a delay of twenty-three days,13 or of four weeks,14 has been considered reasonable. No different rule should be applied than the rule already stated as to demand bills not circulated15 and demand notes.16

3Ridgely v. Davidson, 2 Mill Const. 33. This may not be shown as to the remote indorsee. Cox v. Jones, 2 Cranch, C. C. 370.

4Beebe v. Brooks, 12 Cal. 308; Hunt v. Wadleigh, 26 Me. 271; Jones v. Middleton, 29 Iowa, 188 (the court does not seem to know that it is overruling Hall v. Mono-han, 6 Iowa, 216); Sanborn v. Southard, 25 Me. 409; Godwin v. Davenport, 47 Ma 112; Hart-v. Eastman, 7 Minn. 74: Union Bank v. Ezell, 10 Humph. 385; Corwith v. Morrison. 1 Pin. 489; Jones v. Robinson, 11 Ark. 504; Stewart v. French, 2 Cranch, C. C. 300.

5 Cox v. Jones, 2 Cranch, C. C. 370; Colt v. Bernard, 18 Pick. 260; Tyler v. Young, 30 Pa. 143; Shelby v. Judd, 24 Kan. 161; Stockman v. Riley, 2 McCord, 398; Attwood v.

Haseldon, 2 Bailey, 457; Winston v. Kelly, 33 Tex. 354. Contra, if negotiated after dishonor no new demand is necessary. French v. Jarvis, 29 Conn. 347; Hall v. Mono-han, 6 Iowa, 216 (Seymour v. Van Slyck, 8 Wend. 421, is cited in the last case, but the court did not understand that case at all). See Mc-Ilhenny v. Jones, 6 Har. & J. 256.

6 Levy v. Drew, 14 Ark. 334.

7 Light v. Kingsbury, 50 Mo. 331.

8Bassenhorst v Wilby, 45 Ohio St. 333.

9Hill v. Martin, 12 Mart. (O. S.) 177.

10 Eisenford v. Dillenback, 15 Hun, 23.

11 Jones v. Robinson, 11 Ark. 504 12 See the case in note 10, supra. 13 Goodwin v. Davenport, 47 Me. 112.