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public lands to the States on condition that they establish a college, and later 
donations of money from the sale of public lands were made to each State for 
the benefit of the colleges established under the Morrill Act (1890, 20 Stat. 
417). It is probable that the court would not undertake to question the consti- 
tutionality of an appropriation for general welfare, and that general welfare is 
what Congress takes it to be unless clearly in violation of the constitutional 
limitation.” In United States ». Realty Co. (163 U. S. 427, 1866) the court held 
that “debts” in Article I, Section VIII, included a claim not legal in character 
but based on moral and honorary consideration and under that interpretation 
sustained an appropriation for a bonus to sugar companies to replace a protective 
tariff removed at that time and did not question its constitutionality otherwise. 
The court refused to say there that Congress had the power to appropriate for any 
purpose it might choose to say was in payment of a debt or for general welfare, 
but declared that its decision recognizing a claim and appropriation can rarely, if 
ever, be subject to judicial review. A moral obligation was recognized as a debt 
in United States Sugar Equilization Board ». De Ronde Co. (77 Fed. (2d) 981, 
citing U. S. ». Realty Co). 
The power of the States to curtail their general powers to the extent of enter- 
ing into temporary contracts is well settled (McGee ». Mather (4 Wall. (U. 8.) 
143, I L. Ed. 314 (1896)): Stearns ». Minnesota (179 U. 8. 223, 45 L. Ed. 162 
1900)). 
In summary, the constitutionality of the bill would be free from possibility of 
attack by any State or by an individual taxpayer and would be no invasion of the 
State rights to local self-government. The appropriation, under the general- 
welfare clause, would probably not be reviewed by the courts, and acceptance of 
the provisions by the States would be no unconstitutional surrender of their 
reserved rights and is within their power of making temporary contracts. 
T. FEDERAL AID TO PUBLIC EMPLOYMENT BUREAUS 
During the industrial depression of 1914 no fewer than six bills were introduced 
in Congress to establish a Federal system of employment bureaus. Several well 
attended committee hearings were held; but action was deferred as the result of 
an announcement by the United States Commission on Industrial Relations 
that it was proposing a measure. The commission, however, after long delay 
failed to come forward with a bill. Instead one of the six bills earlier introduced 
was finally reported by the House Labor Committee—too late for action at that 
session. 
Subsequently the Industrial Relations Commission issued a tentative plan for 
a Federal system. It urged the need of a bureau of employment within the 
Department of Labor which would cooperate with State emplovment bureaus. 
There was widespread discussion of this proposal. - 
Meanwhile, many States and cities established public employment bureaus of 
their own. And although Congress failed to provide the central clearing house 
that was needed, the Department of Labor, on its own initiative secured the 
cooperation of the Post Office Department and the Department of Agriculture in 
setting up a makeshift system for job finding on a national scale. It was handi- 
capped by inadequate funds and by an untrained personnel, but it was able to 
give some assistance to the unemployed. 
In 1917 the attention of Congress was again called foreibly to the need of an 
adequate Federal employment system by the emergency of the World War, 
The Robinson-Keating bill was introduced in Congress in December, 1917 with 
strong support, but it was not acted upon. Instead Congress merely appro- 
priated $250,000 to the Department of Labor for the purpose of improving the 
Federal service; and the President supplemented this appropriation by a grant of 
$2,000,000 from the President’s emergency fund. The result was the creation of 
emergency employment offices under Federal direction in all parts of the country. 
During this emergency period, the Secretary of Labor separated the employment 
service from the Bureau of Immigration. At one time there were between 800 
and 900 offices in this Federal system, which proved itself to be invaluable to the 
country during the war and the subsequent demobilization. 
Even while this Federal activity in employment work was at its peak, there 
was general recognition that the employment service as then in operation was 
organized only as an emergency device, and that unless Congress took action to 
put it upon a permanent footing, the end of the war would find the United Rtates 
in the same position as did the beginning, lacking that proven essential to indus. 
fit) efficiency, an adequate, permanént, national svstem of public employment 
UTrealls.