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T HE English rule is that if the commission of a crime is directly in issue in any civil proceeding, it must be proved beyond a reasonable doubt.' The general American rule, on the other hand, is that where proof of crime is necessary in a civil case, it is enough to prove it by a preponderance of the evidence.2 The Illinois Supreme Court has chosen, for reasons which are by no means obvious, to follow the English instead of the general American rule. Unfortunately, however, the later Illinois cases have confused and confounded the subject so that by the year 1925 the decisions were in hopeless conflict. Some followed the English and some the American rule. Thus, we find the following cases in support of the English view: Crandall v. Dawson3 (slander for charge of perjury); Darling v. Banks4 (slander for charge of perjury); Harbison v. Shooks (slander for charge of perjury); McConnell v. Delaware Mutual Safety Insurance Co.6 (Suit to recover insurance money from one alleged to have caused the fire); Germania Fire Insurance Co. v. Klewer7 (Suit on fire insurance policy where defense was made that plaintiff burned the building); Cottam v. National Mutual Church Insurance Co.8 (Action against fire insurance company, defense be-

Degree of Evidence Necessary to Prove Criminal Charge in Civil Suit in Illinois