268 



COUPON CASES. 



Of this amount $1,359,344 was coffee, rep- 

 resenting 85,235 bags, weighing 10,874,750 

 pounds Spanish. 



The maritime movement in 1883 was: 



Agriculture. The yield of several staples in 

 1884 was as follows: Indian corn, 25,535,381 

 litres ; beans, 4,038,783 litres ; potatoes, 1,228,- 

 708 litres; rice, 1,208,716 litres; wheat, 145,- 

 541 litres; sugar, 412,298 kilogrammes; mo- 

 lasses, 7,428,724 kilogrammes. There were in 

 bearing 23,446,278 coffee-shrubs, owned by 7,- 

 490 coffee estates, and they gathered altogether 

 405,053 quintals (of 101 pounds). In the Li- 

 mon district 570,000 banana-trees yielded 425,- 



000 bunches of bananas. 



Education. In 1885 there were in the re- 

 public 176 public primary schools: in the 

 province of San Jose, 1 school to every 1,337 

 inhabitants; in the province of Alajuela, 1 to 

 every 852; in Cartago, 1 to 1,217; in Heredia, 



1 to 1,122; in Guanacaste, 1 to 532; and in 

 the Puntarenas district, 1 school to every 1,540 

 inhabitants. The average for the entire coun- 

 try was 1 school to every 1,023 inhabitants. 

 The national expenditure during the fiscal year 

 1884-'85 was $79,941. Out of 27,109 children 

 of school age, only 12,632 availed themselves 

 during the year of the gratuitous instruction 

 offered them. The expenditure averaged $6.32 

 per pupil, and 43 cents per capita of the popu- 

 lation. Higher instruction is given in three 

 colleges the San Jose University Institute, 

 the Cartago City College of San Luis Gonzaga, 

 and the Heredia City College of San Agustin. 

 The San Jose Institute has a good library. 



Protestantism in San Jose. There is a little 

 Protestant chapel in San Jose" supported by the 

 English and American residents. It receives 

 no aid from any foreign missionary society, 

 but is entirely self-supporting, having about 

 sixty members of the congregation, half as many 

 communicants, and twenty-five children in the 

 Sunday-school. This chapel has been estab- 

 lished nearly twenty years, but has had an or- 

 dained minister but little of that time, the lay 

 members conducting the service after the Epis- 

 copal formula, and reading sermons. There 

 are representatives of five different denomina- 

 tions in the Sunday-school. 



An account of the Central American war 

 will be found under GUATEMALA. 



COUPON CASES. An opinion of great impor- 

 tance was rendered April 20, 1885, by the 

 United States Supreme Court in a series of 

 Virginia bond cases, in which the Court held 

 that a tender of coupons in payment of taxes 

 is equivalent to a tender in money ; that if a 

 tax-collector refuses such tender and seizes the 



property of the tax-payer for non-payment in 

 money, he may be sued for trespass or damages ; 

 and that the collector may be restrained by in- 

 junction from levying on the property of the 

 tax-payer who has tendered the amount of his 

 taxes in coupons. 



The points affirmed arose under the act of 

 the Virginia Legislature of Jan. 26, 1882, and 

 the amendatory act of March 13, 1884. The 

 former provides that tax-collectors " shall re- 

 ceive in discharge of the taxes, license taxes, 

 and other dues, gold, silver, United States 

 Treasury notes, national-bank currency, and 

 nothing else." This excludes receipt of the 

 coupons issued under the act of 1871. The 

 act of March 13, 1884, provides that u no ac- 

 tion of trespass or trespass on the case shall 

 be brought or maintained against any collect- 

 ing officer for levying upon the property of any 

 tax-payer who may have tendered in payment, 

 in whole or in part, any coupon, or paper pur- 



Eorting to be a coupon, cut from bonds of this 

 tate for such taxes, and who shall refuse to 

 pay his taxes in gold, silver, United States 

 Treasury notes, or national-bank notes." The 

 Court held that this legislation impaired the 

 obligation of the contract entered into between 

 the State and its creditors, by the act of 1871, 

 which, after authorizing the issue of bonds for 

 the funding of the public debt, declares that 

 ** the coupons shall be payable semi-annually, 

 and be receivable at and after maturity for all 

 taxes, debts, dues, and demands, due the State." 

 The breach of this contract by the acts of Jan. 

 26, 1882, and March 13, 1884, was pronounced 

 by the Court a violation of Article I, section 10, ' 

 of the Federal Constitution, which declares that 

 no State shall pass any *' law impairing the ob- 

 ligation of contracts." 



The case in which the leading opinion of the 

 Court was rendered was Poindexter vs. Green- 

 how, reported in 114 United States Reports. 

 Greenhow was the treasurer of the city of 

 Richmond. He refused to receive from Poin- 

 dexter coupons of 1871 in payment of taxes, 

 and seized personal property of the latter. 

 Poindexter brought suit for the recovery of 

 this property. The Federal Supreme Court 

 declared that a valid contract had been created 

 by the act of 1871 ; that the obligation of this 

 contract was impaired by the legislation of 

 1882 and 1884, and hence that such legisla- 

 tion was unconstitutional and void. "From 

 the passage of the act of 1871," says the Court, 

 " it became the legal duty of every tax-collector 

 to receive coupons from these bonds, offered 

 for that purpose by tax-payers, in payment of 

 taxes, upon an equal footing, at an equal value, 

 and with equal effect, as though they were gold 

 or silver or legal-tender treasury notes. They 

 were by that act reduced, in effect, into money, 

 and, as between the State and its tax-payer*, 

 were a legal tender as money. And, being not 

 only a law, but a contract, it became, by force 

 of the Constitution of the United States, irre- 

 pealable, and therefore is to-day, what it was 



