arguments, or the instructions," and "the only reference, either direct or remote, dur- ing the whole trial that was made to the question of hypnotism," was the remark of counsel for the defence to the jury that "we might almost say that Gray possessed a hypnotic power over McDonald." Mc- Donald as principal and Gray as accessory, being charged with murder, upon a sever- ance, the latter was tried first and con- victed and afterwards the former was ac- quitted on the ground of self-defense: 3 Am. Lawy. 45; 13 Med. Leg. J. 51. The case of Hayward, tried at Minne- apolis for the murder of Katherine Ging, and afterwards hanged, and the case at Eau Claire, Wisconsin, in which a young man named Pickens was charged with hypno- tizing two young girls, have both been shown to have no connection with hypno- tism; 18 Crim. L. Mag. 100. The facts of both cases may be found in 13 Med. Leg. J. 241. In a California case of a woman on trial for murder, in whose behalf it was alleged that she was hypnotized by her husband, it was held that evidence that she was told by her husband to commit the act does not tend to show that she was hypnotized, and does not render admissible evidence of the effect of hypnotism on persons subject to its influence; 105 Cal. 166. Notwithstanding the drift of opinion in- dicated above there are writers of author- ity on medico-legal subjects who think differently. In discussing the possibility of rape committed upon a person in the hypnotic state, a late work, after alluding to the lack of attention given to hypnotism in England and America, continues: "Like other theories and investigations received at first with ridicule, hypnotism has been placed on a sure scientific basis, thanks to the labor of Charcot and his successors. It has found a place in French, Austrian, and Hungarian law, and must, sooner or later, creep into the Anglo-Saxon. The great French experts in legal medicine, so far as we know, without an exception (Tardieu, Devergie, Brouardel, Vibert, Tourdes, Tour- ette) recognize the possibility that the will may be entirely abolished under hypnotic influence." It is further asserted that the crime mentioned is not frequent, but that it undoubtedly exists in a small number of au- thentic cases. See 2 Witth. & Beck. Med. Jur. 452, where these cases are narrated, and the authorities given. It will be found that they are all open to the criticism and doubt which affect the question of rape on a sleeping woman, and which are inherent in the nature of the crime. In addition to the authorities herein cited see also 2 Ham. Leg. Med. 212; Tourette, Hypnotisme au Point de Vue Médico-Legal; Etude Méd. Lég. sur les Attentats au Mœurs; N. Y. Med. J., Jan. 26, 1895; Gould, Illustr. Dict. Med. sub. v.; Contemp. Rev. Oct. 1890, "Hypnotism and Crime"; Moll, Hypno- tism; Dessoir, Bibliographie des modernen Hypnotismus. HYPOBOLUM (Lat.). In Civil Law. The bequest or legacy given by the husband to his wife, above her dowry. Tech. Dict.