Hennessey, Joseph P.

English

University of Montana School of Law

Montana Law Review
Volume 4
Issue 1 Spring 1943 Article 6
January 1943
Workmen's Compensation - "Work Week"
Joseph P. Hennessey
Follow this and additional works at: https://scholarship.law.umt.edu/mlr
Part of the Law Commons
This Note is brought to you for free and open access by The Scholarly Forum @ Montana Law. It has been accepted for inclusion in Montana Law
Review by an authorized editor of The Scholarly Forum @ Montana Law.
Recommended Citation
Joseph P. Hennessey, Workmen's Compensation - "Work Week", 4 Mont. L. Rev. (1943).
Available at: https://scholarship.law.umt.edu/mlr/vol4/iss1/6
MONTANA LAW REVIEW
WORKMEN'S COMPENSATION-" WORK WEEK"
In House v. Anaconda Copper Mining Company, claimant
received an industrial injury while in defendant's employ.
The' State Industrial Accident Board awarded him $21 per
week, determined by multiplying the daily wage by six. Claim-
ant was only employed five days a week: this was the usual
work week in the mining industry. The Montana Supreme
Court affirmed the action of the Board.
Section 2874 of the Workmen's Compensation Act' defines
"week" as, "... . six working days, but includes Sundays."
Section 2875' defines "wages" as:
".. . the average daily wages received by the employee at
the time of the injury for the usual hours of employment
in a day, and overtime is not to be considered .. .
Section 2912' provides:
".. . For an injury producing temporary total disability
50% of the wage received at the time of the injury shall
be awarded ......
Defendant contended that Section 2912, basing compensation
on the actual wages received at the time of injury, was alone
applicable.
The Court reasoned that under defendant's contention an
employee injured the first day on the job would have his
award computed on the basis of one day's wage. And in the
case of two employers, one employing 200 men for three days
a week, the other 100 men six days a week, the former would
pay out just half as much as the latter, although the man hours
worked would be the same, as would the industrial risks. The
Court further indicated that Section 2912 could not be read
alone, since if the actual wage were to be the guide, overtime
would be counted, and that would nullify the provisions of
Section 2875. Finally, the Court reasoned that the Act is in-
tended to provide compensation in the nature of insurance,'
rather than damages, and to avoid inequalities and chance de-
terminations in the awards made by the Board.
Justices Anderson and Morris dissented on the ground
that the contract of employment between employer and em-
ployee should determine full-time employment. $26.25 was
1(1942) ...... Mont ....... 126 P. (2d) 814.
2R. C. M. 1935, §2874.
'R. C. M. 1935, §2875.
'R. C. M. 1935, §2912.
'Betor v. National Biscuit Co. (1929) 85 Mont. 481, 280 P. 641; Kerns
v. Anaconda Copper Min. Co. (1930) 87 Mont. 546, 289 P. 563.
1
Hennessey: Workmen's Compensation - "Work Week"
Published by The Scholarly Forum @ Montana Law, 1943
NOTE AND COMMENT
earned weekly on a five-day basis here, and 662 percent of
that is $17.50, rather than the sum of $21 arrived at by the
majority.
Thus, the majority opinion uses an arbitrary six-day pe-
riod, irrespective of days actually worked each week, so pro-
ducing certainty and ease of administration; the minority
bases the compensation on the contract of employment. The
extreme position of defendant's counsel was adopted in neither
opinion.
It is believed that, while there is merit in both the major-
ity and minority viewpoints, neither is entirely correct for all
cases.
Most compensation statutes base compensation on the av-
erage weekly wage;' some on the contract of employment;'
some on an outright insurance basis.'
On principle, it is believed that for an incapacitating in-
jury, what the employee would have earned during the period
of disability rather than what he had actually earned during
'With slight variations as to the mode of figuring what constitutes an
average work week, the following twenty-eight states have adopted
this as their basis for determining the amount of compensation to be
paid. The first five states in this category definitely state that the
average work week shall control: N. C. CODE (1939), §8081 (1) (e) ;
TENN. CODE (1932), §6852; VA. CODE (1930), §1887 (2); IND. ANN.
STAT. (Burns, 1933), §40-1701 (c) ; S. C. LAWS 1941, p. 1395. Although
using a different method of computation, these statutes also arrive at
an average work week: CON. LAWS N. Y. (McKinney, 1938), Book 64,
§14; OKLA. STAT. (1931), §13355; TEXAS CIVIL STAT. (Vernon), Art.
8309, §1; IL. REV. STAT. (1935), Ch. 48, 208, §8; IOWA CODE (1931),
§1390, §1397 (1) (3); UTAH REV. STAT. (1933), §42-1-70 (5); GEN.
LAWS R. I. (1938), Ch. 300, Art. 2, §13; REv. STAT. MAINE (1930), Ch.
55, §2 IX (a) (b) ; ANN. LAWS MASS. (1942), Vol. 4, Ch. 152, §1 (1) ;
IDAHO CODE ANN. (1932), §43-1118; COMP. LAWS N. D. Supp. (1925),
Ch. 5, §396 (a) (2) ; OHIO GEN. CODE: (Page, Lifetime ed.), §1465-84;
PuBLic LAWS VERMONT (1933), §6529; ARK. STAT. SUPP. (1942), p.
1090, §12; ALA. Civ. CODE (1923), §7551, §7546; CARROLL'S Ky. STAT.
(Baldwin's Revision, 1930), §4905; MD. ANN. CODE (1939), Art. 101, §80;
W. VA. OFFICIAL CODE (1931), Ch. 23, Art. 4, §14; PUBLIc LAWS N. H.
(1926), Ch. 178, §19, §21; FLA. LAWS (1935), Vol. 1, Ch. 17481, §2
(11) ; CALIF. GEN. LAWS (1923), Act 4749, §9 (2), §12 (1) ; GEN. STAT.
KANS. ANN. (1935), Ch. 44, Art. 5, §511 (1); PENNA. STAT. ANN.
(Purdon), Title 77, Ch. 5, §582. Average monthly wages are used as a
basis in some states: ARxz. CODE ANN. (1939), §56-952; NEv. COMP.
LAWS (Hillyer, 1929), §2706. An even greater extreme is reached by
using average yearly wages: REv. STAT. Mo. (1929), §3320 (a).
'CONN. GEN. STAT., SuPP. (1941), Ch. 280, §704f; GA. CODE (1926), §3154
(32), §3154 (2) ; COMP. STAT. NERRP (1929), §48-117, §48-121, §48-126;
COMP. STAT. N. J., SuPP. (1930), §236-11, §236-12; S. D. CODE (1939),
§64.0405, §64.0404; N. M. STAT. ANN., SUPP. (1938), §156-117, §156-112
(M) ; COLO. SESSION LAWS (1937), Ch. 275, §47(b) ; WIS. STAT. (1939),
§102.11; LA. GEN. STAT. (Dart), §4398.
'Wyo. REv. STAT. (1931), §124-120; ORE. CODE ANN. (1930), Vol. 3,
49-1827; REv. STAT. WASH. (Remington, 1932), Book 4, §2679.
2
Montana Law Review, Vol. 4 [1943], Iss. 1, Art. 6
https://scholarship.law.umt.edu/mlr/vol4/iss1/6
MONTANA LAW REVIEW
a given period prior to disability, should be the test. Practi-
cally, this must be measured by the past in some form. Perma-
nent disabilities should be differentiated from temporary dis-
abilities. The workman who loses an arm (a permanent dis-
ability) has future earning capacity equally reduced whether
at the time he was working one day a week (a depression pa-
riod) or six days a week (a prosperity period); and the de-
pression may well be followed by a period of prosperity, when
he would be able to get full-time work absent the injury. The
problem with reference to temporary disabilities, most of which
will terminate within eight weeks or less, is different. If con-
ditions are such that the injured employee may not return to
full-time work, but may obtain compensation equal to or larger
than the wages at part-time work, there is danger that the
healing period will be prolonged, and that compensation will
be for a period of unemployment rather than actual injury.
As to temporary disabilities, therefore, it would seem that
compensation might well be based on what the employee was
earning at the time of the injury, or on the contract of em-
ployment, while as to permanent disabilities and accident re-
sulting in death, an arbitrary five or six day multiplication of
the daily wage as a method of arriving at the weekly wage is
not without justification.
In some cases, the employee has been on a full-time basis
throughout the preceding year. In others, the employment is
by nature intermittent or seasonal. In still other cases, the
employment is on a part-time basis because of an unusual con-
dition in the industry not normally existing.
For full-time employment, the following methods have
been set up in the various acts: (1) Divide the earnings for
the year preceding by 52;' (2) Multiply the average daily
wage at the time of the injury by 300 and divide by 52 ;1o (3)
Divide the earnings for the six months preceding the injury by
26 ; (4) Multiply the average daily wage for six months pre-
ceding injury by 51/2, 6, 61/2, or 7," according to the number
of days in the employee's customary week. If employment is
'North Carolina, Tennessee, Virginia, Indiana, South Carolina, supra
note 6.
"oNew York, Oklahoma, Texas, Illinois, Iowa, Utah, Massachusetts, and
Maine (uses 250 days as a year), supra note 6.
"Rhode Island, supra note 6.
'California, Kansas, Pennsylvania, supra note 6. Also the states that
hold that a week constitutes 5 days: REv. CoDE Dri . (1935), Ch.
175, 6117 §47; MINN. STAT. (Mason, 1927), Ch. 23A, §4274, as inter-
preted in Modin v. City Land Co. (1933) 189 Minn. 517, 250 N. W. 73.
And the one state that sets it at 6 days: CoMP. LAWS MIcH. (1929),
Ch. 150, §8427.
3
Hennessey: Workmen's Compensation - "Work Week"
Published by The Scholarly Forum @ Montana Law, 1943
NOTE AND COMMENT
stable and continued, it makes no great difference as to which
of these plans is adopted.
Where the employment is naturally intermittent or sea-
sonal, there is much authority that the actual wages deter-
mined by the contract of employment should be the basis of
compensation. This view has been applied in New York to
bricklayers," and under the Federal Act to longshoremen." In
the latter case, a longshoreman worked 182 days out of the
year, and the United States Circuit Court of Appeals said it
would be unfair to apply a mere theoretical earning capacity
having no regard to the actual facts of the case, paying to the
employee more to remain idle than he could earn while at
work.
As to cases where the employment is not normally season-
al, but the employee is on a part-time basis because of some un-
usual or abnormal condition in the industry which is temporary
in character, the New York court has also based its award upon
actual earnings on a part-time basis during the year immediately
preceding the injury. In Remmert v. Weidenmeyer1 the rule
was applied to a baker who had worked six days a week for
ten years until the year preceding the injury, when he was al-
lowed to work as needed, from one to three days a week, be-
cause the bakery was closed.
As indicated, past earnings are used as a basis for deter-
mining the probable basis of future earnings occasioned by
the industrial injury. In the case of a minor," whose wages
may be expected to increase, California has adopted the stand-
ard of what he would probably be able to earn after attaining
twenty-one, but allowing $3 a day for six days a week if prob-
able earnings cannot reasonably be determined. Even for the
minor, however, if the injury is temporary, it is believed that
compensation should be based on a wage actually earned,
thereby adhering to distinctions already indicated.
Thus, while the fixed rule of the Montana Court has some
authority to support it, and is easy of administration, it is be-
lieved that a position more nearly that of the dissenting judges
in the case is the weight of authority and correct on principle
for cases of temporary disability. Most statutes are more pre-
cise on this point than is the Montana Act.
A measure of judicial legislation is present in the case.
It would seem that the existing Act does not necessarily re-
"Littler v. Fuller Co. (1918), 223 N. Y. 369, 119 N. E. 554.
'Marshall v. Mahoney Co. (1932), 54 F (2d) 74.1(1933) 237 App. Div. 147, 261 N. Y. S. 345, 262 N. Y. 534, 188 N. E. 52.
"
6 CALIF. GEN. LAws (1923), Act 4749, §12 (c).
4
Montana Law Review, Vol. 4 [1943], Iss. 1, Art. 6
https://scholarship.law.umt.edu/mlr/vol4/iss1/6
MONTANA LAW REVIEW
quire an inflexible result. In view of the possibilities of ma-
lingering involved, the Legislature might well re-examine the
problem, and attempt some segregation in the law to be ap-
plied to different types of cases.
-- Joseph P. Hennessey.
CUMULATIVE INDEX
Volumes I-IV
The lack of an adequate index materially lessens the value
of a legal publication. Since the first four issues of the Review
constitute sufficient material for binding, it is thought that a
comprehensive index may be appropriate at this time.
It is proposed, therefore, to establish a uniform system of
numbering the various issues, in order to facilitate reference
and citation. In the future, each yearly publication is to be
numbered as a volume. Thus the 1940 issue will be cited as
Volume I, and the present 1943 issue as Volume IV. Volumes
I to IV inclusive will be bound together
5
Hennessey: Workmen's Compensation - "Work Week"
Published by The Scholarly Forum @ Montana Law, 1943


Workmen\u27s Compensation -  Work Week

University of Montana

Montana Law Review Volume 4 Issue 1 Spring 1943 Article 6 January 1943 Workmen's Compensation - "Work Week" Joseph P. Hennessey Follow this and additional works at: https://scholarworks.umt.edu/mlr  Part of the Law Commons Let us know how access to this document benefits you. Recommended Citation Joseph P. Hennessey, Workmen's Compensation - "Work Week", 4 Mont. L. Rev. (1943). Available at: https://scholarworks.umt.edu/mlr/vol4/iss1/6 This Note is brought to you for free and open access by ScholarWorks at University of Montana. It has been accepted for inclusion in Montana Law Review by an authorized editor of ScholarWorks at University of Montana. For more information, please contact scholarworks@mso.umt.edu. MONTANA LAW REVIEWWORKMEN'S COMPENSATION-" WORK WEEK"In House v. Anaconda Copper Mining Company, claimantreceived an industrial injury while in defendant's employ.The' State Industrial Accident Board awarded him $21 perweek, determined by multiplying the daily wage by six. Claim-ant was only employed five days a week: this was the usualwork week in the mining industry. The Montana SupremeCourt affirmed the action of the Board.Section 2874 of the Workmen's Compensation Act' defines"week" as, "... . six working days, but includes Sundays."Section 2875' defines "wages" as:".. . the average daily wages received by the employee atthe time of the injury for the usual hours of employmentin a day, and overtime is not to be considered .. .Section 2912' provides:".. . For an injury producing temporary total disability50% of the wage received at the time of the injury shallbe awarded ......Defendant contended that Section 2912, basing compensationon the actual wages received at the time of injury, was aloneapplicable.The Court reasoned that under defendant's contention anemployee injured the first day on the job would have hisaward computed on the basis of one day's wage. And in thecase of two employers, one employing 200 men for three daysa week, the other 100 men six days a week, the former wouldpay out just half as much as the latter, although the man hoursworked would be the same, as would the industrial risks. TheCourt further indicated that Section 2912 could not be readalone, since if the actual wage were to be the guide, overtimewould be counted, and that would nullify the provisions ofSection 2875. Finally, the Court reasoned that the Act is in-tended to provide compensation in the nature of insurance,'rather than damages, and to avoid inequalities and chance de-terminations in the awards made by the Board.Justices Anderson and Morris dissented on the groundthat the contract of employment between employer and em-ployee should determine full-time employment. $26.25 was1(1942) ...... Mont ....... 126 P. (2d) 814.2R. C. M. 1935, §2874.'R. C. M. 1935, §2875.'R. C. M. 1935, §2912.'Betor v. National Biscuit Co. (1929) 85 Mont. 481, 280 P. 641; Kernsv. Anaconda Copper Min. Co. (1930) 87 Mont. 546, 289 P. 563.1Hennessey: Workmen's Compensation - "Work Week"Published by ScholarWorks at University of Montana, 1943NOTE AND COMMENTearned weekly on a five-day basis here, and 662 percent ofthat is $17.50, rather than the sum of $21 arrived at by themajority.Thus, the majority opinion uses an arbitrary six-day pe-riod, irrespective of days actually worked each week, so pro-ducing certainty and ease of administration; the minoritybases the compensation on the contract of employment. Theextreme position of defendant's counsel was adopted in neitheropinion.It is believed that, while there is merit in both the major-ity and minority viewpoints, neither is entirely correct for allcases.Most compensation statutes base compensation on the av-erage weekly wage;' some on the contract of employment;'some on an outright insurance basis.'On principle, it is believed that for an incapacitating in-jury, what the employee would have earned during the periodof disability rather than what he had actually earned during'With slight variations as to the mode of figuring what constitutes anaverage work week, the following twenty-eight states have adoptedthis as their basis for determining the amount of compensation to bepaid. The first five states in this category definitely state that theaverage work week shall control: N. C. CODE (1939), §8081 (1) (e) ;TENN. CODE (1932), §6852; VA. CODE (1930), §1887 (2); IND. ANN.STAT. (Burns, 1933), §40-1701 (c) ; S. C. LAWS 1941, p. 1395. Althoughusing a different method of computation, these statutes also arrive atan average work week: CON. LAWS N. Y. (McKinney, 1938), Book 64,§14; OKLA. STAT. (1931), §13355; TEXAS CIVIL STAT. (Vernon), Art.8309, §1; IL. REV. STAT. (1935), Ch. 48, 208, §8; IOWA CODE (1931),§1390, §1397 (1) (3); UTAH REV. STAT. (1933), §42-1-70 (5); GEN.LAWS R. I. (1938), Ch. 300, Art. 2, §13; REv. STAT. MAINE (1930), Ch.55, §2 IX (a) (b) ; ANN. LAWS MASS. (1942), Vol. 4, Ch. 152, §1 (1) ;IDAHO CODE ANN. (1932), §43-1118; COMP. LAWS N. D. Supp. (1925),Ch. 5, §396 (a) (2) ; OHIO GEN. CODE: (Page, Lifetime ed.), §1465-84;PuBLic LAWS VERMONT (1933), §6529; ARK. STAT. SUPP. (1942), p.1090, §12; ALA. Civ. CODE (1923), §7551, §7546; CARROLL'S Ky. STAT.(Baldwin's Revision, 1930), §4905; MD. ANN. CODE (1939), Art. 101, §80;W. VA. OFFICIAL CODE (1931), Ch. 23, Art. 4, §14; PUBLIc LAWS N. H.(1926), Ch. 178, §19, §21; FLA. LAWS (1935), Vol. 1, Ch. 17481, §2(11) ; CALIF. GEN. LAWS (1923), Act 4749, §9 (2), §12 (1) ; GEN. STAT.KANS. ANN. (1935), Ch. 44, Art. 5, §511 (1); PENNA. STAT. ANN.(Purdon), Title 77, Ch. 5, §582. Average monthly wages are used as abasis in some states: ARxz. CODE ANN. (1939), §56-952; NEv. COMP.LAWS (Hillyer, 1929), §2706. An even greater extreme is reached byusing average yearly wages: REv. STAT. Mo. (1929), §3320 (a).'CONN. GEN. STAT., SuPP. (1941), Ch. 280, §704f; GA. CODE (1926), §3154(32), §3154 (2) ; COMP. STAT. NERRP (1929), §48-117, §48-121, §48-126;COMP. STAT. N. J., SuPP. (1930), §236-11, §236-12; S. D. CODE (1939),§64.0405, §64.0404; N. M. STAT. ANN., SUPP. (1938), §156-117, §156-112(M) ; COLO. SESSION LAWS (1937), Ch. 275, §47(b) ; WIS. STAT. (1939),§102.11; LA. GEN. STAT. (Dart), §4398.'Wyo. REv. STAT. (1931), §124-120; ORE. CODE ANN. (1930), Vol. 3,49-1827; REv. STAT. WASH. (Remington, 1932), Book 4, §2679.2Montana Law Review, Vol. 4 [1943], Iss. 1, Art. 6https://scholarworks.umt.edu/mlr/vol4/iss1/6MONTANA LAW REVIEWa given period prior to disability, should be the test. Practi-cally, this must be measured by the past in some form. Perma-nent disabilities should be differentiated from temporary dis-abilities. The workman who loses an arm (a permanent dis-ability) has future earning capacity equally reduced whetherat the time he was working one day a week (a depression pa-riod) or six days a week (a prosperity period); and the de-pression may well be followed by a period of prosperity, whenhe would be able to get full-time work absent the injury. Theproblem with reference to temporary disabilities, most of whichwill terminate within eight weeks or less, is different. If con-ditions are such that the injured employee may not return tofull-time work, but may obtain compensation equal to or largerthan the wages at part-time work, there is danger that thehealing period will be prolonged, and that compensation willbe for a period of unemployment rather than actual injury.As to temporary disabilities, therefore, it would seem thatcompensation might well be based on what the employee wasearning at the time of the injury, or on the contract of em-ployment, while as to permanent disabilities and accident re-sulting in death, an arbitrary five or six day multiplication ofthe daily wage as a method of arriving at the weekly wage isnot without justification.In some cases, the employee has been on a full-time basisthroughout the preceding year. In others, the employment isby nature intermittent or seasonal. In still other cases, theemployment is on a part-time basis because of an unusual con-dition in the industry not normally existing.For full-time employment, the following methods havebeen set up in the various acts: (1) Divide the earnings forthe year preceding by 52;' (2) Multiply the average dailywage at the time of the injury by 300 and divide by 52 ;1o (3)Divide the earnings for the six months preceding the injury by26 ; (4) Multiply the average daily wage for six months pre-ceding injury by 51/2, 6, 61/2, or 7," according to the numberof days in the employee's customary week. If employment is'North Carolina, Tennessee, Virginia, Indiana, South Carolina, supranote 6."oNew York, Oklahoma, Texas, Illinois, Iowa, Utah, Massachusetts, andMaine (uses 250 days as a year), supra note 6."Rhode Island, supra note 6.'California, Kansas, Pennsylvania, supra note 6. Also the states thathold that a week constitutes 5 days: REv. CoDE Dri . (1935), Ch.175, 6117 §47; MINN. STAT. (Mason, 1927), Ch. 23A, §4274, as inter-preted in Modin v. City Land Co. (1933) 189 Minn. 517, 250 N. W. 73.And the one state that sets it at 6 days: CoMP. LAWS MIcH. (1929),Ch. 150, §8427.3Hennessey: Workmen's Compensation - "Work Week"Published by ScholarWorks at University of Montana, 1943NOTE AND COMMENTstable and continued, it makes no great difference as to whichof these plans is adopted.Where the employment is naturally intermittent or sea-sonal, there is much authority that the actual wages deter-mined by the contract of employment should be the basis ofcompensation. This view has been applied in New York tobricklayers," and under the Federal Act to longshoremen." Inthe latter case, a longshoreman worked 182 days out of theyear, and the United States Circuit Court of Appeals said itwould be unfair to apply a mere theoretical earning capacityhaving no regard to the actual facts of the case, paying to theemployee more to remain idle than he could earn while atwork.As to cases where the employment is not normally season-al, but the employee is on a part-time basis because of some un-usual or abnormal condition in the industry which is temporaryin character, the New York court has also based its award uponactual earnings on a part-time basis during the year immediatelypreceding the injury. In Remmert v. Weidenmeyer1 the rulewas applied to a baker who had worked six days a week forten years until the year preceding the injury, when he was al-lowed to work as needed, from one to three days a week, be-cause the bakery was closed.As indicated, past earnings are used as a basis for deter-mining the probable basis of future earnings occasioned bythe industrial injury. In the case of a minor," whose wagesmay be expected to increase, California has adopted the stand-ard of what he would probably be able to earn after attainingtwenty-one, but allowing $3 a day for six days a week if prob-able earnings cannot reasonably be determined. Even for theminor, however, if the injury is temporary, it is believed thatcompensation should be based on a wage actually earned,thereby adhering to distinctions already indicated.Thus, while the fixed rule of the Montana Court has someauthority to support it, and is easy of administration, it is be-lieved that a position more nearly that of the dissenting judgesin the case is the weight of authority and correct on principlefor cases of temporary disability. Most statutes are more pre-cise on this point than is the Montana Act.A measure of judicial legislation is present in the case.It would seem that the existing Act does not necessarily re-"Littler v. Fuller Co. (1918), 223 N. Y. 369, 119 N. E. 554.'Marshall v. Mahoney Co. (1932), 54 F (2d) 74.1(1933) 237 App. Div. 147, 261 N. Y. S. 345, 262 N. Y. 534, 188 N. E. 52."6 CALIF. GEN. LAws (1923), Act 4749, §12 (c).4Montana Law Review, Vol. 4 [1943], Iss. 1, Art. 6https://scholarworks.umt.edu/mlr/vol4/iss1/6MONTANA LAW REVIEWquire an inflexible result. In view of the possibilities of ma-lingering involved, the Legislature might well re-examine theproblem, and attempt some segregation in the law to be ap-plied to different types of cases.-- Joseph P. Hennessey.CUMULATIVE INDEXVolumes I-IVThe lack of an adequate index materially lessens the valueof a legal publication. Since the first four issues of the Reviewconstitute sufficient material for binding, it is thought that acomprehensive index may be appropriate at this time.It is proposed, therefore, to establish a uniform system ofnumbering the various issues, in order to facilitate referenceand citation. In the future, each yearly publication is to benumbered as a volume. Thus the 1940 issue will be cited asVolume I, and the present 1943 issue as Volume IV. VolumesI to IV inclusive will be bound together5Hennessey: Workmen's Compensation - "Work Week"Published by ScholarWorks at University of Montana, 1943

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