lative Action.) The Court held that it could,
however, confer School Suffrage as "the whole primary school system is
confided to the Legislature and its officers are not mentioned in the
constitution." By this decision women can have no other form of the
franchise except by constitutional amendment.

OFFICE HOLDING: Hundreds of women are serving as officers and members
of school boards throughout the State, as township school inspectors
and as county school commissioners and examiners.

A number are acting as deputy county clerks, and one as deputy clerk
of the United States District Court. The latter frequently opens the
court. Women serve as notaries public.

For thirty years women have filled the office of State Librarian, the
present incumbent being Mary C. Spencer.

Dr. Harriet M. C. Stone has been for several years assistant physician
in the Michigan Asylum for the Insane at Kalamazoo.

The State Industrial School for Girls has two women on the Board of
Guardians, one of whom, Allaseba M. Bliss, is the president and is
serving her second term of four years, having been reappointed by Gov.
Hazen S. Pingree.[339] Since 1899 the law requires women physicians in
asylums for the insane and other State institutions where women and
children are cared for.

In the autumn of 1898 Mrs. Merrie Hoover Abbott, law-partner in the
firm of Abbott & Abbott of West Branch, was nominated on the
Democratic ticket as prosecuting attorney of Ogemaw County. She was
elected and entered upon her duties Jan. 1, 1899. _Quo warranto_
proceedings were instituted by Attorney-General Horace M. Oren to test
her right to the office, and October 17 the Supreme Court filed its
opinion and entered judgment of ouster. In the meantime Mrs. Abbott
had discharged successfully the duties of the position. The opinion
was as follows: "Where the constitution in creating a public office is
silent in regard to qualification to office, _electors_ only are
qualified to fill the same, and since under the constitution women are
not electors, they are not eligible to hold such offices. The office
of prosecuting attorney is a constitutional office which can only be
held by one possessing the qualification of an elector."

From this opinion Justice Joseph B. Moore dissented, making an able
argument. In closing he said:

The statutes of this State confer upon woman the right to
practice law. She may represent her client in the most important