point of constitutional law. It also decides those which have
been heard in one of its divisions and in which the divisional
court is in favor of reversing the judgment appealed from. An
affirmance by the divisional court is final, but if it inclines
to a reversal the judges communicate their opinions to the full
court, which also reads the printed briefs submitted on the
original argument, and then without any further oral hearing
pronounces final judgment. Four judges, therefore, at least,
must concur to accomplish a reversal. Should the full court in
any case be equally divided, the judgment appealed from stands.

Under the Constitution of California (Art. VI, Sec. 2) the
Supreme Court, which consists of seven judges, ordinarily sits in
two departments. Three judges can render a decision, but the
judgment does not go into full effect for thirty days unless
three, including the Chief Justice, have given it their approval.
The Chief Justice also, with the concurrence of two of his
associates, or four of these without his concurrence, can direct
that any cause be heard before a full court within thirty days
after judgment by a department court. He can also order the
removal into the full court of any cause before judgment.

In Michigan only five out of the eight judges sit to hear a case,
and if one of them files an opinion dissenting from that of his
associates, the losing party can demand a rehearing before the
full court.

Neither the bar nor the bench are quite satisfied with such
methods of appellate procedure. The Ohio scheme is excellently
adapted for the dispatch of business, but may prevent an oral