(294) by command of Pope Alexander II., by the consent, and in the presence of the king, for settling the disputed superiority between the archbishops, it was decreed that bishops' sees should be transferred from towns to cities. This decree, he thinks, probably gave rise to the opinion that a bishop's see constituted a city, in the case also of the new foundations. 1 Wooddes. Lect. 180, citing Ingulph. Hist. 92, 93. Spelman alludes to the same decree and its consequences, in confining the title of city to the towns or boroughs in which such sees were located; (civitatis titulus apud cathedrarios tantum burgos remanebat.) Spelman, voc. Burgus. See Borough, Burgus. The practice of locating bishops' sees in cities, may be traced to a constitution of the Emperor Zeno: Ekáσrn módis idiov 'εníσKOTOV ἐχέτω ; Let every city have its own bishop. Cod. 1. 3. 36. As to the modern distinction, in England, between a city and any other incorporated town or borough, it seems to be little more than nominal. Both cities and boroughs have the same form of local government, and both send special representatives to parliament, the only difference being, that in the one case these representatives are or have been called citizens, and in the other burgesses. Spelman, voc. Burgus. Municipal Corporation Act, cited 3 Steph. Com. 193, et seq. In Brande's Dictionary, it is said that a city differs in no respect but that of superior dignity, from another borough. See P. Cyclopædia. And the distinction between citizen and burgess seems now to be disregarded. See 1 Man. & Gr. 1, note (a). (295) The distinction between private and public rights, in the definition of civil injuries, has been properly rejected by Mr. Stephen, who, in place of the definition of Blackstone, describes civil injuries as "the violation of private or public rights, when considered in reference to the injury sustained by the individual, and consequently as subjects for civil redress or compensation," and distinguishes them in this respect from crimes, which "are the violation of public or private rights, when considered in reference to their evil tendency as regards the community at large, and accordingly visited with punishment." 3 Steph. Com. 356, and note (d).