Judicial History	23

tions of the river, yet here the Compact is given controlling
power over a statute which could be effective beyond
tidewater.

	E. Hendricks v. Virginia (1882). Hendricks, a citizen of
	Maryland, was indicted in Virginia for fishing with nets
	and seines opposite a regularly hauled fishing landing on
	the Virginia shore of the Potomac River. The act was a
	clear violation of the concurrent laws on the Potomac
	River. His plea was that according to the Compact he
	was entitled to be tried in a Maryland Court. However,
	he was convicted by the Virginia court, and the conviction
	was affirmed by the Supreme Court of Appeals of that
	state (75 Va. 934) .

	The Court cited and discussed the provision in Article 8
	of the Compact that fishing laws for the Potomac River

`shall be made with the mutual consent and approba
tion of both states.'
	The effect of this article is to give the State of Vir
	ginia concurrent jurisdiction with the State of Mary
	land, over the Potomac River from shore to shore . . . . ,
	to enact such laws, with the consent and approval of
	Maryland, as may be deemed necessary and proper
	for the preservation of fish in said waters. The power
	of a state to enact laws, carries with it the judicial
	power to enforce them. A law without a sanction is
	no law; and an act of legislation without power to
	enforce it, is not a law. The judicial, unless otherwise
	stipulated in the Compact, is co-extensive with the
	legislative jurisdiction.

The Court was saying, then, that the power given by the
Compact for the states to enact concurrent laws carried
with it logically the power for both states also to enforce
the laws.

	Hendricks pointed to Article 10 of the Compact, by
	which "piracies, crimes and other offenses" committed in
	the Potomac River, by a citizen of one state against a
	citizen of the other, were to be tried by the state of which