On March 30, I920 the Supreme Court of Appeals of Virginia decided three cases,2 Burks, J., speaking for the court in each case, thereby establishing an unenviable record in the field of vicarious liability that we trust will never be repeated by any other commonwealth. Each case was submitted on an agreed statement of facts. In each case the automobile used in the illegal transportation of intoxicating liquor was forfeited, although the interveners were innocent and free from fault. In Buchholz v. Commonwealth the owner of the car (Mr. Buchholz, a hotel owner in the District of Columbia) instructed his chauffeur to take the car to a repair shop in the District. The chauffeur violated the owner's instructions and drove into Virginia and was later arrested in Richmond, Virginia, charged with the illegal transportation of ardent spirits. Under a statute of the District of Columbia, the chauffeur became a thief before taking the car from the District. whether the right given the chauffeur by the owner was that of custody or possession. The Virginia court disregarded the District of Columbia statute and declared that: