With some modifications, in order to ob viate the constitutional questions which might arise under it in this country, the Tor rens system has been adopted- in ten states, and in Hawaii and the Philippines. The acts were not uniform, and most of them have been ^amended once or more: Califor nia (1897); Colorado (1903); Illinois (the act of 1895 was declared unconstitutional; an act passed in 1897 was held valid ; a com pulsory act was adopted in 1910); setts £1898); Minnesota (1901, and a new act In 1905); New York (1908, which was pass ed after an elaborate study and report by a special commission); North Carolina (1913; in effect January 1, 1914); Ohio (1913, in effect July 1, 1914); Oregon (1901) ; Wash ington (1907) ; Hawaii (1903); Philippines (1908). Hawaii and the Philippines followed the Massachusetts act.
Acts have been held constitutional in 'Rob inson v. Kerrigan, 151 Cal. 40, 90 Pac. 129, 121 Am. St. Rep. 90, 12 Ann. Cas. 829 ; Peo ple v. Crissman, 41 Colo. 450, 92 Pac. 949; People• v. Simon, 176 Ill. 165, 52 N. E. 910, 44 L. R. A. 801, 68 Am. St. Rep. 1:75 -(it is said that the Illinois act has been before the supreme court of that state 61 times); Tyler v. Judges, 175 Mass. 71, 55 N. E. 812, '51 L. R. A. 433, see also 179 U. S. 405, 21 Sup. Ct. 206, 45 L. Ed. 252 (numerous other Massa chusetts cases have followed Tyler from Minot v. Cotting, 179 Mass. 325, 60 N. E. 610, down to Cohasset v. Moors, 204 Mass. 173, 90 N. E. 978) ; State v. Westfall, 85 Minn.' 437, 89 N. W. 175, 57 L. R. A. 297, 89 Alm St. Rep. 571. The first act in IllinoiS (1895)' was declared unconstitutional in People 'v.
Chase, 165 Ill. 527, 46 N. E. 454, 36 L. R. A. 105. An earlier Ohio act was declared un constitutional; State v. Guilbert, 56 Ohio St. 575, 47 N. E. 551, 38 L. R. A. 519, 60 Am. St. Rep. 756.
A state act requiring persons (including non-residents) owning land to establish title by judicial proceedings before properly con stituted tribunals is valid under the inher ent power of the state to legislate as to • the title to the soil within its confines ; Ameri can Land Co. v. Zeiss, 219 U. S. 47, 31 Sup. Ct. 200, 55 L. Ed. 82 (a California act pass ed after the San Francisco fire).
See also Ochoa v. Hernandez y Morales, 230 U. S. 139, 33 Sup. Ct. 1033, 57 L. Ed. 1427.
See William C. Niblack, An Analysis of the Torrens System, written as the result of many years' experience in titles under the Torrens System, but from a standpoint somewhat critical of it.
The first Canadian act was British Colum bia (1871), then Ontario (1885), but only as to part of the province. There are acts in all the provinces except Quebec, Prince Edward Island, New Brunswick and New foundland. The Irish System exists under the act of 1891. Registration is compulsory in London, but is voluntary in other parts of England and in Wales.
See the Report of the Uniform Law Com missioners on the Torrens System in Amer. Bar Assoc. Rep. 1913, giving the above sum mary.
A state commission fully considered the introduction of the system into Pennsylvania and reported In favor of it, but as requiring an amendment to the constitution.