nor is it likely to, unless Teutonic philosophy pervades and overcomes the world.

The German Foreign Office is believed to be too conversant with the principles of jurisdiction to maintain seriously that the United States has violated international law in establishing Rintelen's guilt and in dealing with him as a criminal. The suggestion that the treatment of him as such constitutes internationally illegal conduct must be taken to be merely a pretext for a threat to resort to illegal measures which, even as so disguised, is none the less perceived in its true aspect. The nature of the effort to bring about the release of this particular individual betrays the fact that German authority in Imperial hands is still obsessed with an amazingly distorted notion of American character and institutions. No proposal accompanied by such a threat could have won acceptance here. Nor is any proposal concerning the action of the United States, likely to fare better if acceptance necessitates the perversion of criminal justice.

CHARLES CHENEY HYDE.

IN MEMORIAM

LOUIS RENAULT

International law has lost its most distinguished exponent in the death of Monsieur Louis Renault on February 7, 1918, unexpectedly, without a suggestion of warning, after meeting his class on that day, and for the last time. A Frenchman by birth and the trusted adviser and representative of the French Government on numerous occasions, he was yet a citizen of the world, revered by his former students, holding honorable and responsible positions in well-nigh every country, respected by foreign governments, and treated with deference by their delegates in international conferences, where power and political considerations too often outweigh merit and the regard for justice. Well advanced in years he was born on May 21, 1843- he might reasonably have hoped to render still further services to international law and to his country in its defense of that law, in the conference at the close of the war, of which he would undoubtedly have been a member. And if he had thus rounded out the labors of a lifetime, he would have made humanity still further his debtor.

Monsieur Renault was a teacher by profession; an international lawyer by practice; a writer on occasion. He entered the Paris Law School as a student in 1861, and, after a course of exceptional distinction, graduated with highest honors. From 1868 to 1873 he was professor of Roman and of commercial law in the University of Dijon, and from 1873 until the very day of his death, he was professor in the Faculty of Law of the University of Paris. For the first three months after his transfer to Paris he taught criminal law, substituting for the professor of that subject. During 1874-1875 he substituted for the professor of international law, and continued, after the death of the titular professor in that year, in charge of the course until 1881, when he himself was appointed to the chair of international law, occupied by Royer-Collard from 1830 to 1864 (for whom it was originally created), and by Charles Giraud from 1865 to 1875. In addition, he was professor of international law in the School of Political Sciences, and in both of these positions he came into contact with students from all countries, whom he largely attracted by his presence in the Faculty of Law and in the School of Political Sciences, where he taught the law of nations as a branch of general jurisprudence and of positive law, bringing to its exposition and its application the conceptions of the philosopher, the experience of the historian, and the training of the jurist. His success in the classroom was phenomenal and would alone have placed him among the glories of each of the institutions with which he was connected. He was, as he himself modestly said, a professor at heart.

His career as a practitioner of international law began in 1890, when he was appointed jurisconsult of the Ministry for Foreign Affairs by M. Ribot, then Minister for Foreign Affairs, who had the post specially created for him. From his entrance upon the performance of its duties until his death he was the one authority in international law upon whom the Republic relied. Under his eye the foreign policy of France passed in so far as it depended upon the law of nations; through his hands the projects of the Foreign Office passed, putting into effect the principles of international justice, directed and controlled in each instance by a generous, enlightened, seasoned, and passionately honest intellect. In appreciation of his services in the Ministry for Foreign Affairs he was accorded the titular rank of Minister Plenipotentiary and Envoy Extraordinary.

It would be wearisome to enumerate the international gatherings in which he represented his government and where, respected as a

plenipotentiary of France, he gradually became recognized as the counselor of the conference and of its members as well.

In the different and yet not unrelated field of international arbitration he enjoyed a preeminence which was not contested by his contemporaries, and as arbiter he both won and merited the approbation of the nations in dispute.

Of the many international congresses in which he participated the two Hague Peace Conferences and the London Naval Conference of 1908-1909 may be mentioned. In the first of these M. Renault was reporter of the Second Commission, which adapted the principles of the Geneva Convention to maritime warfare, and he was also reporter as well as member of the most important committee of the conference, appointed to draft the Final Act of its labors.

In the second of the Hague Peace Conferences M. Léon Bourgeois appropriately referred to him as exercising "a sort of magistracy"; and it may be said- indeed, it is not too much to say - without disrespect to any of his colleagues, that that august body consisted of two groups of members: M. Renault and the other delegates. He was both chairman and reporter of the committee to draft the Final Act, and he made its oral report to the Conference; he was reporter for the convention relating to the opening of hostilities, for the revised convention adapting the principles of the Geneva Convention to maritime warfare, for the convention creating an international prize court, and for the convention on the rights and duties of neutral Powers in naval war. He ably seconded M. Léon Bourgeois, first delegate of France at both the Hague Conferences, to whom is justly due the credit for the peaceful settlement convention of the first and the success of the second, in so far as it succeeded, in the matter of arbitration and peaceful settlement.

But, in addition to his duties as a plenipotentiary of France, he was in a very real sense the friend and adviser of the delegates at large, working in harmony with the German delegation, on the one hand, and the British delegation, on the other, and placing himself unreservedly, in and out of the conference, at the disposal of the American delegates. One instance among many may be cited. A Belgian delegate was anxious to present a project guaranteeing in a very large measure the immunity of private property, foreseeing that the plan presented by the United States could not hope to triumph. M. Renault entered the conference chamber while the Belgian delegate was at work on a

more modest proposal, with the result that M. Renault sat down beside him, took pen and paper in hand, and, after saying that he did not approve of the principle, drafted the project presented by the Belgian delegation in accordance with the views and desires of his colleague.

In the London Naval Conference, M. Renault, in addition to being a representative of France, was chairman of the committee of the whole and of the committee of examination, and reporter general. He prepared the masterly report upon the Declaration of London, which unfortunately has gone down like many a ship it was drafted to

preserve.

In international arbitrations—to mention only those of The Hague under the provisions of the peaceful settlement conventionhe was arbiter in the Japanese House Tax case of 1905, between Japan, on the one hand, and Germany, France, and Great Britain, on the other; the Casa Blanca case of 1909 between Germany and France; the Savarkar case of 1911 between France and Great Britain; president of the tribunal in the Canevaro case of 1912 between Italy and Peru; arbiter in the Carthage case of 1913 between France and Italy, and in the Manouba case of 1913 between the same countries.

M. Renault's career as professor and international lawyer was so distinguished that, in comparison, his career as a writer may seem to be overshadowed; but it should not, and, indeed, it can not, be overlooked, as it would alone have sufficed to hold his name in grateful remembrance in two domains of the law. In conjunction with M. Lyon-Caen, a fellow student, a fellow professor in the Faculty of Law as well as in the School of Political Sciences, and the friend of a lifetime, he published a Compendium of Commercial Law, in two volumes, an elaborate treatise on commercial law in eight volumes (which reached a fourth edition two years ago), and a manual of commercial law, the twelfth edition of which appeared in 1916.

In the field of international law, as such, he has many an article and monograph devoted to special phases of the subject, some large collections of treaties and documents, and more than one book to his credit. His admirable introduction to the Study of International Law, published in 1879, and which has been translated into Japanese, he modestly called "the work of a beginner," and toward the end of his career, in a little work of almost the same size entitled The First Violations of International Law by Germany, dealing with the invasion of Luxemburg and Belgium by that Power in violation of the treaties

to which it was at the time a party, he brought to bear the principles of law, of justice, and of fidelity to the pledged word which he had professed and applied during a lifetime.

Among the texts which he edited, or with whose publication he was associated, but one need be mentioned, which, like all of his work is a model of its kind. It is a small volume and bears the simple title: The Two Peace Conferences. Collection of Texts Adopted by the Conferences of 1899 and 1907. Supplementary Documents of 1909. In appearance M. Renault was tall and well formed, with finely molded features, beaming with benevolence and good will, outwardly suggesting the simple curate whose precepts he inwardly and devoutly followed. So modest and unassuming, so unconscious of his greatness, and so unaware of the services which he had rendered in behalf of justice, upon which peace between nations can only be based, he was astounded when the Nobel Committee honored itself by awarding him a peace prize in 1907.

He was, indeed, although he knew it not, "the very oracle of international law."

JAMES BROWN SCOTT.

THE SEVERANCE OF DIPLOMATIC RELATIONS BETWEEN PERU

AND GERMANY

Communicated by Dr. Juan Bautista de Lavalle, of the Peruvian Society of International Law

The Peruvian steamer Lorton was sunk by a German submarine, which captured it after having hoisted the French flag. This vessel had started from Caleta-Buena for Bilbao but was wrecked at a distance of four miles from the harbor of Suances upon the Spanish coast. After the completion of the act the Peruvian Legation at Berlin received instructions to inform the Imperial Government that the attack upon this neutral vessel, within neutral waters, with a cargo destined for a non-belligerent country, and outside the zone forbidden to navigation, constituted an unjustifiable attack against international law against which Peru protested, demanding at the same time in a peremptory manner that the German Government should repair the damage occasioned, pay indemnities, and condemn the act by punishing its authors.