were reasonable. The court cited several cases as precedence for a mutual benefit society to legally change its by-laws. The court also viewed the issue in reference to the "nature and purpose of contracts in light of their objectives." The court continued by further explaining that while contracts vested rights to both member and organization, it did not allow for the organization to use its reserved power to 
amend or add stipulations without taking into account the rights of the other. "Such a construction would put the rights of one party to the contract wholly at the mercy of the other." 

The second question addressed by the court pertaining to the validity of the by-laws binding Anne Rehan. The court argued that the mutual benefit society made no allegation that the member was sane or insane; nor was it alleged that deceased died of an inflicted pistol wound either intentionally or unintentionally. The defense case rested upon the by-law and the mere allegation that the member committed suicide, not taking into account how the actual act occurred. In Travelers' Insurance Company vs. Nickles, 88 Md. 470, the court addressed the issue of a death resulting from a gunshot being considered suicide. "[T]he law presumes the wound was the result of accident, and the burden of proof is upon the defendant to show by a preponderance of testimony the wound was intentionally self-inflicted, and that it was not the result of accident." 

In its decision, the Court of Appeals affirmed the decision of the lower court to award Mrs. Rehan the full amount of the benefit.
 

Roads in Montgomery County, 1777-1794
Montgomery County was formed in 1777 from Frederick County. An examination of the minutes of the county court, found in (Minutes) in series C1134 and dating from 1779, shows a low level of activity regarding roads. Just as telling is the low number of road laws passed by the General Assembly. Much of the interest in roads during this time period centered in the areas between Western Maryland and Baltimore City in order to facilitate the transportation of agricultural products and other goods. Although Georgetown remained an important port, the transportation concerns were focused on the Potomac River, rather than on land routes except for those terminating at the river.
 
 

Most of the entries in the court minutes consist of the annual list of road areas and appointments of road overseers who were responsible for maintenance. The number of road areas changed very little, ranging from thirty-eight to forty-two. The following examples of road descriptions illustrate their usefulness, or lack thereof, for locating routes, identifying local features, and placing individuals.
 
 

• From the house where the courts are held to Rock Creek Bridge near James Smith's former plantation, from the courthouse to a bridge on Rock Creek near William Beckwith's plantation, from Rock Creek Church to George Town Road, and from the fork of the road below Rock Creek Church to the Rock Creek bridge below James Beall's;

• From the fork of the road near Brock Macbees to the county line above Little Bennetts Creek; 

• From the east side of Jacobs Bridge to the Sugarland road leading from O'Neill and Deakens Mill on Seneca Creek; 

• From the Mill Branch to George Robertson's bridge and from William Beckwith's plantation to Dents Mill; 

• From the bridge on Rock Creek to the crossroads going by W. Carroll's plantation and from Thomas Williams' mill to the Watery Branch near where Thomas Roby formerly lived; 

• From Green's bridge to the fork of the road commonly called Buceys Road near Joshua Dorsey's quarter; 

• From Captain Johns Meeting House to the plantation of Zachariah Macubbin; 

• From the fork of the road below Seneca to the fork of the road above Richard Thomas' quarter; 

• From the bridge near George Snell's to the fork of the road below Richard Thomas' from there across Hawlings River to the road near Green's Bridge; 

• From Rock Creek near Benjamin Rickett's to George Robertson's bridge and from William Beckwith's plantation to Williams' Mill; 

• From Captain John's Run, to include the bridge and causeway near James Moore's to the courthouse; 

• From Muddy Branch to Benjamin Edwards's from above Thomas Pack's plantation and by the south side of theQuince Orchard hill to the old road through Abraham Holland's plantation and with the old road to a road through Abraham Holland's lane and with that lane to Zachariah Maccubbin's mill;

• From Conrad Myers's Ferry on Potomac River to the road commonly called Wilcoxens Road to the road from Benjamin Edwards to the mouth of the Monocacy River.

The other references to roads in the minutes may be sparse, but do correlate to two pieces of legislation relating to Montgomery County. In November 1791 the justices considered straightening of specific roads authorized by Ch. 32, Acts of 1790. They approved parts of the routes, and deferred the rest until the court term. Funds were allocated for the road from Georgetown to Captain John Bridge and from Georgetown to the courthouse. In March 1793 the court appointed commissioners to lay out two roads from Conrad Myers' ferry on the Potomac River, as designated by Ch. 53, Acts of 1791.

Also in March 1793, the justices directed the surveyor to lay out a road from the plantation of Thomas Plater through the land of John Rawlings to the public road at Logg Town.

Only one other piece of legislation dealt with Montgomery County roads. In 1792 several individuals petitioned the General Assembly for a road from the Frederick County line to the mills of Thomas Morton and Zachariah Maccubbin and then to the main road that went to Georgetown. Through Ch. 26 the court was authorized to construct the road and the petitioners were made responsible for paying damages to land owners.