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PORTIA ANTE PORTAS: WOMEN AND THE LEGAL PROFESSION IN EUROPE, ca. 1870-1925.

In 1895, at a time when agitation for opening the Austrian medical profession to women had reached an unprecedented level, a physician named Wilhelm Svetlin responded to the rising demands with what bordered on disbelief. "The most remarkable thing," Svetlin wrote, "is that the champions of university study for women, just like unreasoning children, desire first and demand most loudly precisely that which is the most difficult, the medical profession. One might think that it would be more natural that woman pursue first a profession more agreeable and appropriate for her: chemistry, pharmacy, the philosophical subjects, or, aspiring higher, the legal profession, the office of a defender, in which the well-known and well-tested verbal skills of the female sex would be particularly beneficial."'

Svetlin's argument that women lawyers should precede women physicians, although plausible, was certainly a minority view. In every major European country, in fact, women gained access to the practice of medicine before they could practice law, in some cases several decades earlier. In Holland, France, the Scandinavian countries, and a handful of Swiss cantons, women did gain access to at least some fields of legal practice around the turn of the century. Yet in the United Kingdom, Belgium, Germany, Italy, the Iberian countries, and the successor states to the Russian and Austro-Hungarian empires, they did not win admission to the bar until after World War I. In Svetlin's Austria, women could not even matriculate in the legal faculties of the universities until 1919; in Hungary, they could not become attorneys until after World War II. [2]

Scholars in women's history have done surprisingly little research into the entrance of European women into the legal profession. Several older surveys of women's educational and professional achievements provide some useful information on various "firsts" but offer little serious comparative analysis. [3] Recent surveys of the history of European women have generally neglected the legal profession, especially in comparison with the attention lavished on female physicians. [4] There has been no comprehensive survey comparable to Thomas Bonner's excellent study of the first generation of female medical students. [5]

Historians of the legal profession have also displayed little interest in issues of gender. Some recent works have omitted entirely discussion of issues related to female attorneys, while others have mentioned them only in passing. [6] In the most ambitious comparative study of European lawyers yet published, Hannes Siegrist supplies basic information about the first female candidates for the bar in Germany, Italy, and Switzerland; but he neglects many important sources and does not address seriously questions about women and the professions. [7]

This essay explores the struggles by European women (and their male supporters) to gain access to the legal profession, primarily as private attorneys; the arguments that they used; and the resistance that they encountered from defenders of the status quo. Two main questions will guide the investigation: why did law prove to be more resistant to female practitioners than did medicine; and what "factors" help to explain the earlier or later opening of the bar to women in the various countries? As will be seen, the first question can be answered in a more coherent and convincing fashion than can the second.

For some scholars, the first question is not a serious one. Peter Gay, for example, has written, "It was only natural that in women's struggle for access to the professions, it was medicine that opened its doors to them [first]." With regard to the United Stares, Barbara Harris made the same point at greater length: "Practicing law was even more incompatible with nineteenth-century ideas about women than was practicing medicine. Female doctors could claim that their careers were natural extensions of women's nurturant, healing role in the home and that they protected feminine modesty by ministering to members of their own sex. By contrast, women lawyers were clearly intruding in the public domain explicitly reserved for men." In the case of Ontario, Gidney and Millar have argued, "In law the struggle was of a different order [from medicine] since nor only the worksites but the entire culture of work left few niches where women's claims could be lodged except for the blunt and radical one of equal rights." [8 ]

Historians of England have offered less global explanations for the precedence of medicine. Nellie Franz suggested that English barristers resisted admission of women to their ranks for so long because they "had established off-duty customs which were nor altogether praiseworthy--that is, they had taken to amusements somewhat beneath a group of learned men." More recently, Leslie Howsam has noted that in law, in contrast to medicine, "there was no precedent of earlier participation like midwifery, and thus little impetus for a social movement of protest against exclusion." According to W. J. Reader, "the long struggle to get women into medicine seems to have engrossed the strength of campaigners for professional status for women, leaving little to spare for any other battle." [9]

That one of the English women who tried and failed to gain access to the bar before 1914 was Chrisrabel Pankhurst, who certainly had enormous energy for other battles, clearly shows the limited value of Reader's argument. [10] In general, interpretations based on the experience of single countries fall short of explaining the universal lag of the admission of women to law as compared to medicine. This phenomenon occurred, after all, in nations with very different "public domains": states with common law and those with civil law, states where most lawyers were civil servants and those where most were in private practice, and states where the bar was a closed corporation and those with no restrictions on pleading in court.

Even Gay's argument from "nature" has its flaws. Anyone familiar with the history of the admission of women to the medical profession knows how widespread and virulent the opposition was. Numerous physicians and laypersons found the idea of women studying topics such as anatomy and venereal disease to be highly "unnatural." Especially for many male physicians, women's talents for nurturing qualified them very well for becoming nurses but nor for the practice of medicine. Many individuals convinced of the possibility of, and need for, female physicians still found the prospect of women studying among male medical students with a "reputation for rowdiness, bawdiness, and general aggressive masculinity" unacceptable." In Europe as in North America, such concerns led to creation of many more women's medical schools than law schools and to serious consideration of separate-sex medical instruction almost everywhere.

Opposition to female physicians was, in fact, both more vocal and more violent than opposition to female attorneys. In the large collection of opinions about women's fitness for university studies published in 1897 by the German journalist Arthur Kirchhoff, for example, the views of thirty-eight physicians fill 112 pages, whereas those of six professors of law occupy only twelve. [12] The largest body of source materials for European women's history in the nineteenth century, the Gerritsen Collection, also contains significantly more items related to admitting women to medicine than to law. [13]

Among early female medical students, Elizabeth Garrett was forced out of London's Middlesex Hospital in 1861 by protests from male students. Nine years later, Sophia Jex-Blake and several other women encountered more violent opposition in Edinburgh, where male students rioted to prevent women from attending clinical instruction. Even at the University of Zurich, the pioneer in granting medical degrees to women, men locked the German Franziska Tiburtius and a Russian colleague in a cloakroom in 1871. Worse befell Pilar Taurequi, the first Spanish woman to study medicine, who had rocks thrown at her in Barcelona in 1881. Blanche Edwards-Pilliet, who campaigned vigorously to gain access to externships and internships at Parisian hospitals, was hanged in effigy by male opponents in 1884. [14] A decade later, Maria Montessori faced "vulgar mockery and tricks" as the first woman to study anatomy at Rome. As German women began to gain access to universities in their own country at the turn of the century, the large st organized protest came from male medical students at the University of Halle. Even after World War I, the medical faculty at the University of Budapest initiated a movement to remove women from Hungarian universities. 15

The history of women law students records few similar incidents. Not long after the riot at Edinburgh, the English feminist Jessie Boucherett predicted accurately, "It is not probable that the same spirit of antagonism towards the efforts of women will be roused in the Legal, as has been shown in the sister learned profession." When Christabet Pankhurst--not the first British woman to complete legal studies--walked up to receive her LL. B. at Victoria University in 1904, she experienced what her sister described as "a humorous hostile demonstration by some of the men students." A similar scenario played out in France, where the first women to attend lectures in the Parisian faculty of law did so without incident. When, in 1892, Jeanne Chauvin became the first French woman to defend a doctoral thesis in law, male students did cause enough of a disturbance that the proceedings had to be continued in camera. [16] In the United States, the contrast between the two fields manifested itself very early at the Unive rsity of Michigan, were male medical students "ridiculed women in their classes, [but] most of the male law students welcomed their female classmates." American attorney Mary Greene went so far as to suggest in the late 1880s that for women law was an "even more appropriate endeavor than the pursuit of medicine" because of "the unpleasant features of a course of medical study in a mixed school." [17] Although hers was clearly a minority view, it does indicate that Wilhelm Svetlin was neither alone nor completely wrong-headed in thinking women might well pursue law before trying to enter medicine.

With regard to the second main question examined in this essay--what explains the timing of the opening of the legal profession in various countries-- there is no widely accepted interpretation comparable to the "natural" precedence of admission to medicine before law. Most scholars who have written about women's struggle to gain access to the bar stress the great difficulties involved; none ever admits that the process was particularly easy in a certain country. This pattern holds true even for histories of American women lawyers, who from the perspective of most European countries did have an easy path. The most egregious example of this type of argument, however, occurs in Constance Backhouse's examination of women and the law in Canada during the nineteenth century. Backhouse cites without comment the words of Clara Brett Martin, Ontario's first female barrister, when she was called to the bar in 1897. "If it were not that I set out to open the way to the bar for others of my sex," Martin proclaimed, "I would have given up the effort long ago." [18] At the time of this comment, Martin had reached the ripe old age of twenty-three.

Some studies of individual countries do suggest factors that could be employed in comparative analysis. Speaking of the United States, Robert Stevens asserted that "women found it more difficult to become lawyers than doctors ... because the legal profession was institutionalized and had, in general, been granted licensing powers earlier than the medical profession." In an examination of women in health professions in England, Anne Witz concluded that "the resources of male power were most effectively institutionalized within the modern university and professional corporations, whilst the nineteenth-century patriarchal capitalist state was the weakest link in the chain of patriarchal closure." A contrasting view, however, appears in the work of Richard Abel, who in examining the rapidly growing numbers of women lawyers throughout the western world since 1970 has attributed major influence to "the university, which displaced or reduced the importance of apprenticeship in the common law and rapidly expanded" i n the civil law world as well. [19]

The most extensive comparisons of women's access to higher education and the professions have come from the German scholar Ilse Costas. In a series of articles Costas has proposed a number of criteria useful in explaining national differences in these areas. With regard to the legal profession, however, she offers a focused comparison only of France and Germany. Costas attributes the earlier opening to women of the French bar to: 1) a more democratic parliament; 2) a more diverse system of higher education; 3) relatively low prestige for the learned professions (compared to graduates of the grandes [acute{s{]co1es); and 4) high demand for university-trained personnel (compared to the oversupply of graduates in Germany). [20] This essay will argue that Costas' criteria are not only problematic for explaining French and German differences, but have even more limited usefulness for broader comparisons.

In examining the processes by which women in different European countries entered the legal profession, this essay will first look in some detail at four cases where debates and decisions centered on individuals. In chronological order of their law degrees, these four cases involved Lidia Po[ddot{e}]t in Italy, Emilie Kempin-Spyri in Switzerland, Marie Popelin in Belgium and Jeanne Chauvin in France. Poet, Popelin, and Chauvin faced virtually identical legal systems, all based on the French Civil Code and related decrees, where attorneys had to earn a law degree and then go through an apprenticeship or stage before joining a corporate body of their colleagues. Kempin, in the canton of Zurich, faced a different situation. After examination of these four cases, the essay will look more briefly at developments elsewhere in Europe.

Italy. Lidia Po[ddot{e}]t, a member of the Waldensian sect from the town of Pinerolo near Turin, is the most elusive of these four pioneers. [21] According to one source, she was not the first modern Italian woman to earn a law degree, being preceded by a certain Maria Maddalena Canedi, who graduated from the University of Bologna in 1870 but never tried to practice. [22] Po[ddot{e}]t herself studied at the University of Turin after passage of the Italian statute of 1876 that reconfirmed women's right to matriculate, something that had never been officially barred. She received her degree in 1881. Over the next two years she fulfilled the requirements for admission to the bar by an apprenticeship in a lawyer's office, probably that of her brother, and by regular attendance at the courts. All of this took place without arousing any

controversy.

In 1883, Po[ddot{e}]t applied for admission to the Council of the Order of Barristers of Turin; by a vote of 8-4 she was approved. Only after she had inscribed her name on the register (albo) of lawyers did controversy begin, with an intervention by the Attorney General that led to an overturning of the Council's action by the Court of Appeals. The Court of Cassation later upheld this decision. In both houses of the Italian legislature, which were dominated by lawyers, interpellations by supporters of Po[ddot{e}]t received official replies that the matter was one for the courts; no legislation appears to have been introduced. Pout herself worked in her brother's law office without being able to appear in court. In 1900, she did reach an international audience through a speech at a conference on penal law held in Brussels. [23]

A total of six Italian women earned law degrees by the turn of the century, but not until 1912 did another, Teresa Labriola, launch a new assault on the bar. By that time, Labriola had already served for a decade as a lecturer in law at the University of Rome. She had the same experience as Po[ddot{e}]t: successful registration on the albo at Rome, a challenge from the Attorney General, and defeat in the regional Courts of Appeals and Cassation. [24] Italian women gained access to the bar via legislation adopted in 1919 by the legislature elected before World War I, although by 1929 only fifteen women had qualified as attorneys. Women obtained the right to become notaries, which required lower academic qualifications than the bar, under Mussolini's regime; the first, Adelina Portecorvo, began work in 1933. Not until 1963 could Italian women become judges. [25]

Belgium. Marie Popelin was a thirty-seven-year-old schoolteacher when she entered the Free University of Brussels in 1883, three years after it first admitted women. At that rime Belgian universities did not require a classical secondary diploma for matriculation. She received her degree in 1888, before any Belgian university had granted a medical degree to a woman. [26] In Belgium, law graduates had to swear an oath as an attorney before beginning their probationary or apprenticeship period, but the Attorney General in Brussels refused to allow Popelin to do so. Her appeal, supported by several leading lawyers, was rejected in December 1888 by the Court of Appeals and in November 1889 by the Court of Cassation. The latter suggested that the question of women lawyers was one for the legislature, which did consider the issue in January 1890. According to Popelin's most vocal supporter, the lawyer Louis Frank, "In the vote, all of the liberal left pronounced in favor of women lawyers; the clerical majority opp osed them." [27]

Marie Popelin went on to have an active career as the leader of the Ligue beige du droit des femmes and as editor of its journal, La Ligue. She attended numerous international feminist meetings between 1889 and 1909. She died in 1913, however, without ever gaining admission to the bar. The legislature did reconsider the issue of female attorneys in 1912, but rejected it again. At that time, minister of state Charles Woeste commented, "I do not see the urgency, apart from a question of pure gallantry." [28]

As in Italy, only after World War I did the Belgian legislature change its mind. The socialist Emile Vandervelde, a long-time supporter of female attorneys, was minister of justice when the new bill was first proposed, though out of office by the time it passed in 1922. The lower house voted 124-1 in favor, indicating strong Catholic, as well as liberal and socialist, support. About two dozen women qualified as attorneys by the end of the decade. As in Italy, the notariat, which did not require a full law degree, remained a male monopoly for longer. In fact, Belgian women gained access to the bench in 1947, to positions as notaries only in 1950. [29]

France. French women had never officially been barred from academic study and degrees, though only in the 1860s did they attempt to gain accss to the baccalaureat and university faculties. In Paris, the Faculty of Law first allowed women to audit courses during the 1870s. Regular study began in the mid-1880s, with several foreigners preceding the first French women. The first woman to graduate was not Jeanne Chauvin, but a Romanian named Sarmisa Bilcesco, who received her licence in 1887 and her doctorate in 1890, after completing a dissertation on the legal rights of mothers in France. The following year, false reports circulated in western Europe that she had been admitted to the bar in Romania, when in fact she had had a similar experience to Lidia Po[ddot{e}]t, being supported by practicing lawyers but barred from registration by government officials. [30]

Jeanne Chauvin herself received her licence in 1890, her doctorate in 1892, with a dissertation on the history of occupations open to women. She did not immediately apply for admission to the bar but began instead to teach courses on law at several girls' lyc[acute{e}]es in Paris. When she did apply in 1897, she met the same fate as Po[ddot{e}]t and Popelin. In contrast to these two predecessors, however, she did not appeal to higher courts. [31] Yet Chauvin had much greater success in the French legislature, despite its domination by lawyers. The Chamber of Deputies first discussed her case in March 1898. After new elections in the midst of the Dreyfus Affair brought in a more left-leaning chamber--including Chauvin's brother Emile [32]--radicals led by Ren[acute{e}] Viviani convinced their colleagues to declare admission of qualified women to the bar a "matter of urgency." With government support, a law opening the legal profession to women passed the Chamber in June 1899, the Senate in November 1900. This law passed despite grave concerns about overcrowding of the legal profession, which had been growing twice as fast as the medical profession since the foundation of the Third Republic. [33]

Jeanne Chauvin was not, however, the first woman to take the oath as a French lawyer. Preceding her by a week was the Russian-born but French-educated Eva Balachowsky-Petit, who had not taken an active part in the struggle to open the profession. Neither of these pioneers ever established a large practice. Only with Marie Verone, the fifth woman admitted to the French bar, did a true activist emerge. As Christine Bard has shown, Verone and several other women lawyers played leading roles in French feminism during the interwar period. [3.4] This early success in becoming attorneys did not translate, however, into similarly early access to other domains of the legal profession. French women could not become judges until 1946, notaries until 1948. [35]

Switzerland. As was the case with Chauvin, Emilie Kempin-Spyri was not the first woman to study law in her native country. During the first wave of Russian students at the University of Zurich in the early 1870s, Elizaveta Boguslavskaia enrolled for one year in the faculty of law. When Russian women studying medicine at Zurich were ordered to leave in 1873 by Tsar Alexander II, one of them, Stefania Berlinerblau, went to Bern to complete her medical training. Under the name of Fanny Berlin, she went on to earn a law degree as well, in 1878. She did not practice law, however, but moved to the United States where she became "chief surgeon at the New England Hospital for Women and Children." [36]

Almost forgotten two decades ago, Kempin, whose sister-in-law was the author of Heidi, has become much better known recently as the result of several scholarly studies and a very popular historical novel. Eveline Hasler's Die WachsfL[ddot{u}]felfrau, published in 1991, implied through its title that Kempin, like the mythical Icarus, had tried to soar too high, something that she herself suggested in an article published in Germany in 1897. [37]

Kempin was a married mother of three when she began to study law at the University of Zurich in 1883, after passing the Swiss Matura examination, which required Latin but not Greek. She wrote a thesis on liability in certain commercial transactions, received her doctorate in 1887, then worked briefly in the office of a prominent attorney. Neither a degree nor an apprenticeship, however, was required to plead in court in the canton of Zurich, which along with several other cantons had abolished the "lawyers' monopoly" in the 1870s. [38] Kempin nonetheless failed to gain access to the courts because she did not meet the only requirement, possession of the rights of an "active citizen," a status open only to men. She appealed the decision of the local courts to the Swiss Federal Court, which decisively rejected her arguments based on existing law. Kempin then attempted to become a lecturer (Privatdozentin) in Roman law at the University of Zurich, an innovation rejected by the university senate (by a vote of 14-7) and by the cantonal Education Council. [39]

In the fall of 1888, Kempin and her family left for New York, where she first found work as an advisor for the Arbitration Society. After a brief attempt to establish a private law school, in 1890 she began lecturing in Roman law at the University of New York (later NYU) Law School and offered general courses on law through the Women's Legal Education Society. her husband returned to Zurich with the children, however, and Kempin decided to follow them in the summer of 1891. [40] She appealed to the cantonal legislature to allow women with law degrees to practice as attorneys, in effect proposing higher standards for women than for men; but this plea also failed. She made a second application to be a Privatdozentin, this time on the basis of a new publication on American law as well as her dissertation. The university senate at Zurich again rejected her application, but the Education Council now overrode the decision and appointed her the first female lecturer in the history of Swiss universities. [41]

Kempin taught Roman law at Zurich from 1892 to 1895, though she never attracted many students. More successful were public lectures on law and her work in organizing a legal counseling service (Rechtsschutzstelle) aimed primarily at women. In 1895 she gave up her lectureship and moved to Berlin, where she continued her work as a popular speaker and provider of legal counsel. In September 1897, buffeted by personal and professional difficulties, as well as conflicts with leading German feminists, she entered a mental hospital. She died of cancer in a Swiss asylum in 1901. [42]

Ironically, by the time of Kempin's death women could become attorneys in the canton of Zurich. Her petition to the cantonal legislature had not been forgotten: the issue arose again in 1892 and 1895, the latter discussion spurred by a petition from the Swiss Association for Reform of Women's Education. The issue of opening the bar to women became part of a referendum in 1898 that also included reintroduction of educational requirements for attorneys and creation of a fee schedule. All these items passed, that on women lawyers by the narrow margin of 21,787 to 20,122. The first woman to qualify under the new regulations was the German-born Anna Mackenroth, whose legal studies at Zurich had included courses from Kempin. Although Mackenroth did not have to worry about the rights of an "active citizen," she did have to establish Swiss citizenship before she could practice. A total of a dozen foreign women earned degrees from Zurich's faculty of law and political science before a second Swiss woman did in 1912. [43]

Several other Swiss cantons, including St. Gall, Geneva, Basel City, and Neuenburg, also opened the bar to women before 1914. In each case, new legislation rather than a court decision proved necessary. Yet on a nation-wide basis, admission came in 1923 as a result of a decision by the Federal Court on a case from the canton of Freiburg, which rested much more on the issue of freedom of occupation than the issue of "active citizenship." Even in the pioneering canton of Zurich, however, women could not become judges until 1962. [44]

United Kingdom. Efforts to open the British legal profession were much more diffuse than those discussed so far, as no single individual became the focus of attention. In nineteenth-century England, barristers and solicitors had separate apprenticeship systems. Neither branch required a university degree, nor did a degree provide access to practice. As early as 1871, an Englishwoman named Eliza Orme began attending lectures on law at University College, London, several years before women gained access to London degrees. In 1873 she apprenticed in the "chambers of a sympathetic barrister at Lincoln's Inn." In that year, the Women's Education Union under Maria Grey petitioned unsuccessfully for general admission of women to the Lincoln's Inn lectures, a step that Leslie Howsam considers "more of a political gesture on the part of educational reformers than a practical plan to begin the systematic study of law." Orme herself went on to win a first prize in Roman law and the Hume Scholarship at University Colleg e in 1876, although she did not receive her LL. B. until 1888. From the mid-1870s until after the turn of the century, she ran a successful practice with a series of female partners doing commissioned work--or "devilling"--for as many as a dozen male solicitors. [45] Although several sources indicate that the Law Society turned down a woman who wanted to become a solicitor in either 1876 or 1879, Orme herself told an American visitor in 1888 that she had "never applied for admission to the bar." [46]

The next two women to earn law degrees in the United Kingdom did so in Ireland, Letitia Alice Walkington in 1889 and Frances Helen Gray in 1890. At Oxford, Cornelia Sorabji from India followed the course of study for a Bachelor of Civil Laws degree from 1888 to 1892. With the support of Benjamin Jowett of Balliol College, she took and passed the BCL examination in 1892; but, as with all Oxbridge women at that time, she did nor receive a degree. [47] Individual efforts to enter practice all came to naught. In 1891, Lincoln's Inn rejected the application of a Miss Day. In Scotland, which had a system based more on Roman law, Margaret Hall in 1900 "applied to the Society of Law Agents for permission to enter for the Solicitors' Preliminary Examination" and won some support; but the courts decided she was not a "person" as intended by the Solicitors' Act. Perhaps the most interesting case was that of Bertha Cave, whom the barristers of Gray's Inn were willing to admit in 1902 until they determined that they coul d not do so without the permission of the judges. An appeal tribunal chaired by the Lord Chancellor also refused to set a precedent, a ruling that carried over to the cases of Christabel Pankhurst and Ivy Williams, who after passing the BCL examination at Oxford in 1902 had earned an LL. D. from the University of London in 1903. [48]

Not until 1912 did a private member of Parliament introduce a bill that would allow women to become solicitors. Its slow progress led four women--two each from Oxford and Cambridge--to launch a direct assault on the Law Society, with one of them, Gwyneth Bebb, appealing her rejection in the courts. Despite having her case argued by Lord Robert Cecil, Bebb lost on the issue of women not being "persons," with the judge citing the seventeenth-century jurist Sir Edward Coke on the unfitness of women to be lawyers. New legislation, with at least tacit government support, was introduced in Parliament in March 1914; but no vote took place before the outbreak of the war. During the war, the Law Society continued to lobby vigorously against admission of women. Not until after the "Khaki Election" of December 1918, in which women over thirty had voted for the first time, did Parliament pass the Sex Disqualification Removal Act in December 1919. [49] The first two women in the United Kingdom to qualify as barristers di d so in Dublin in 1921, shortly before Irish independence. The first in England was Ivy Williams in 1922. Cornelia Sorabji even returned from India to collect an Oxford degree and gain admission to the British bar. [50]

Russia. Tsarist Russia did not have anything resembling a western European legal profession until the period of the Great Reforms. An imperial decree of 1864 created a new category of sworn advocates (prisiazhnyi poverennyi), who needed to have a university degree and undergo five years of apprenticeship with a lawyer or in the courts. These sworn advocates could join Councils of the Bar, although for many years these existed only in Moscow, St. Petersburg, and Kharkov. The shortage of sworn advocates helped lead to a new decree in 1874, which created a less prestigious class of private advocates (chastnyi poverennyi), who did not need degrees and could practice only in the courts where they had been examined and registered. Holders of law degrees could serve as private advocates while undergoing their apprenticeships; after Alexander III imposed quotas on non-Christian lawyers, many Jewish "advocates in training" ended up having long careers as private advocates. [51]

Although a decree of January 1871. had excluded women from all areas of public service except for elementary teaching, midwifery, physicians' assistants, and telegraph offices, neither of the decrees on the legal profession explicitly barred women. Women had been able to plead before pre-reform local courts, and after 1874 a few did register as private attorneys. The Minister of Justice, Count Pahlen, published a circular opposing this development in April 1875; but an appeal by a woman named E. F. Kozmina led both the State Senate and the Court of Cassation to declare that the law did not forbid female attorneys. Pahlen then turned to Alexander II, who in January 1876, despite Russia's shortage of attorneys, barred women from serving as private advocates. [52] In this case at least, women did have a basis to protest new exclusions.

At that time, with Russian universities closed to women, there was no question of their becoming sworn advocates. Even Anna Evreinova, who received a law degree from the University of Leipzig in 1873-one of handful of foreign women to earn German degrees in that era-could not begin an apprenticeship in Russia. [53] As Ruth Dudgeon points out, however, the "pre-reform legal structure continued to operate in Siberia until 1898" and neither sworn nor private advocates were necessary in "the lowest courts (mirovoisud)." Thus women could practice law in some areas or cases at the level of amateur pettifoggers, a situation that led some western observers to believe that the Russian legal profession was much more open to women than it was. [54]

After the Revolution of 1905, law faculties were founded at women's higher courses that had become universities in all but name. Yet in 1908, graduates who had been accepted as advocates in training by male colleagues had their registrations overturned by the courts. A bill allowing female attorneys passed the Duma in 1912 but failed in the State Council. A second bill passed the Duma in 1.9 1.3; this time the State Council delayed action until 191.6, when--apparently on instructions from the Empress Alexandra--it again rejected opening the legal profession to women. [55] The Provisional Government under Alexander Kerensky finally passed legislation opening the bar to women in June 1917, three months after removal of restrictions on the number of Jewish advocates. [56]

Germany. In Imperial Germany, becoming a lawyer required possession of a diploma (Abitur) from the classical Gymnasium, [57] three years of university study, passage of a state examination (in Prussia called the Referendarpr[ddot{u}]fung), an apprenticeship of several years in the judicial and administrative system, and passage of a second examination (the Assessorenpr[grave}{fung). National legislation in 1878 separated attorneys more clearly from judicial officials and created semiautonomous lawyers' chambers to regulate the profession. Only six months of an attorney's training, however, was with a practicing attorney, the rest remained tied to the bureaucracy. This dominance of judges and other civil servants over private attorneys indicated, according to Hannes Siegrist, that "in terms of general prestige German attorneys had an inferior status compared with Italian or French barristers." [58]

This structure meant that German women, as Costas has pointed out, faced a daunting series of obstacles in gaining access to the legal profession. Anna Evreinova's early law degree remained a unique occurrence, even though two law professors at Leipzig stated in late 1873 that they favored continuing to allow women to audit courses in their faculty, even if coeducational study of medicine was unsuitable. [59] When, in the late 1880s and early 1890s, various womens groups petitioned the state governments and the Reichstag to open the Abitur and university study to women, most concentrated on the fields of teaching and medicine. It is difficult to determine whether they considered careers in law less desirable or simply less likely to be achieved. During the 1890s only two other German women, Anita Augspurg and Marie Raschke, followed Anna Mackenroth in obtaining law degrees in Switzerland; both returned to Germany and were active in debates about the new German Civil Code. [60]

Discussion of admission of German women to the legal profession thus did not, at first, focus on women with degrees who were claiming the right to practice. Even Alix Westerkamp, the first German woman to earn a law degree in Germany--from the University of Marburg in 1907, without formal matriculation-did not become a center of controversy. Faculties of law did not offer particularly vigorous opposition to women students: in 1902, seven of nine Prussian faculties favored admission of women with the Abitur, whereas only five of nine medical faculties did so. The next year, two of three legal faculties in Bavaria approved of admitting women; and in 1905, law professors at Leipzig in Saxony declared that qualified women should not be prevented from studying on account of their sex. [61]

Controversy arose much more, especially in the eyes of government officials, about whether women could be admitted to the study of law and still--in the short or long term-be excluded from the state examinations and civil service careers pursued by most male students. Concern about this problem among members of the Prussian Ministry of State served to delay for several years the opening to women of matriculation at Prussian universities. When this did finally occur in 1908, an explicit proviso barred women from state examinations and apprenticeships in law. In Bavaria, where matriculation opened in 1903, no regulation prevented women from taking the first state examination; yet the first few graduates in law appear to have believed they were barred and applied for special permission to take it. Bavarian women were excluded from civil service training and the second examination, although in 1909 one of the first graduates, Marie-Delia Droste (married name Schmidbaur) gained admittance as a trainee at two dist rict courts (Amtsgerichte) before the Minister of the Interior intervened. Three years later, Florentine Neuhaus (Rickmers) did receive provisional permission to begin work as a trainee while still being barred from the second examination. [62]

Not until after the revolution of 1918-19, the granting of women's suffrage, and adoption of a constitution guaranteeing equal rights for all citizens did German women gain access to the bar. Even then, explicit national legislation proved necessary, as individual states moved hesitantly to open examinations and professional associations of judges and attorneys vociferously objected to women entering their ranks. Although some consideration was given to opening only practice as attorneys to women, the legislation adopted in July 1922--when the Social Democrat Gustav Radbruch was Minister of Justice in Josef Wirth's second cabinet--covered all branches of the legal profession. Before the end of the 1920s some areas of Germany had female judges, a phenomenon as yet unknown in France, Belgium, Switzerland, and Italy. [63] The gains of the Weimar Republic were, however, almost completely reversed during the Nazi era. After World War II, American occupation forces appointed the first women judges in Bavaria. [64]

Austria. The legal profession in the Austrian half of the Habsburg monarchy closely resembled that in Imperial Germany, especially in the dominance of civil servants over private attorneys. Compared with their German sisters, Austrian women did have earlier access to the classical secondary diploma (Matura), open to them from 1872, and slightly greater opportunities to audit university courses in the 1880s and early 1890s. They could not earn degrees without formal matriculation, however; and no Austrian woman pursued a Swiss law degree before the turn of the century. [65]

Whereas in Germany the individual states opened their universities to women at different times but did so completely (except for theology), in Austria all universities moved simultaneously but did so faculty by faculty. Philosophical faculties opened first in 1897, followed three years later by the medical faculties. In 1900 the government also consulted the law faculties about admission of women; that in Vienna, led by Edmund Bernatzik, voted by a narrow margin in favor. [66] Yet the government did not open legal studies at that time; most scholars argue that the issue of keeping women out of the civil service, so controversial in Germany, proved decisive in delaying legal study in Austria. [67]

After Prussian universities opened matriculation in 1908, the Association for Expanded Women's Education in Vienna petitioned the government to open Austrian legal faculties, explicitly accepting that women would not gain access to the political bureaucracy. Even this appeal, however, failed. The continuing blockage led Bernatzik to establish a private, two-year "Law Academy" for women during World War I, the only such initiative in Europe. Only after the overthrow of the Habsburgs did the provisional government--with a Socialist as Minister of the Interior and Education--finally open the legal faculties in April 1919. Of the sixty women who matriculated in law in Vienna in 1919, over fifty percent were Jewish; even into the mid-1930s, Jewish women provided over twenty percent of the female law students at Vienna. [68]

Although the constitution of the first Austrian republic, adopted in October 1920, seemed to promise access for women to all areas of the legal profession, none achieved a judgeship before more authoritarian, anti-feminist, and anti-Semitic policies emerged in the 1930s. The first woman attorney, Marianne Beth, who already had a doctorate in oriental languages, received a law degree in 1921, worked briefly as a university lecturer, then began her apprenticeship. Beth completed her training in 1928, but was stricken from the register of attorneys in 1938, after Nazi Germany annexed Austria; she ended her career at Reed College in Oregon. Only in 1947 did the first female judges in Austria, Johanna Kundmann and Gertrude Sollinger, take the bench. [69]

Other Countries. [70] Scandinavian countries were among the earliest to admit women to the bar. Sweden, which resembled the canton of Zurich in having open access to pleading in court, opened law degrees to women in 1895, twenty-five years after medical degrees. In 1897, the legislature changed the wording of regulations to say "person" rather than "man," allowing women to act in the courts. The first Swedish woman to earn a doctorate in law, Elsa Eschelsson at Upsala in 1898, did not choose to become a attorney, deciding instead upon a career as a lecturer at her alma mater. Apparently frustrated by her failure to gain promotion, Eschelsson committed suicide in 1911. The first two Swedish women to practice law were Eva Anden and Mathilda Stael von Holsteen; by the 1930s about fifty other women had followed their lead. [71] The Grand Duchy of Finland, although under Russian rule, had court regulations like Sweden's, in that attorneys did not have a monopoly on pleading. Women began to appear in court in 1895 , although as late as 1930 there was only one female attorney in independent Finland. [72]

In Norway, the first woman to earn a law degree was Marie Katrine Doll, in 1890. Five years later the bar in the capital city of Christiania (Oslo) voted in favor of allowing women to become attorneys. Not until 1904, however, did legislation open practice to women. Among the pioneer attorneys, both Sofie Corradine Schjott and Ruth Sorenson Brie became judges by the mid-1920s. [73] In Denmark, a decree of May 1882 allowed women to take lower-level examinations in law that did not require university training. When Nanna Berg, who had passed this examination, tried in 1888 to appear in court in place of an attorney for whom she worked, she was "turned away--which a man similarly qualified would not have been. She instituted proceedings but lost, and this verdict was confirmed by the supreme court." [74] Once Henny Magnusson became the first Danish woman to earn a law degree in 1905, however, a law opening the bar to women passed the following year. One of the first female attorneys, Nina Bang, became Denmark's minister of public instruction in the 1920s. [75]

In the Netherlands, where holders of law degrees did not have to undergo any apprenticeship, the first woman to earn a degree was Elisabeth van Dorp in 1899. She did not try to practice but chose an academic career as a lecturer at the University of Utrecht. Four years later, however, Adolphine Kok (married name van den Hoek-Kok) did attempt to join the bar in Rotterdam and had the unique experience of being accepted without government interference. The Netherlands was thus a rare European country where women gained access to the legal profession without legislation. By the late 1920s sixty-five Dutch women had become lawyers. [76]

The Iberian nations admitted women to the bar at roughly the same time as did most of the major nations except France. In Portugal, Regina de Quintanilha earned a law degree from the University of Coimbra in 1913 but could not practice until the passage of legislation in 1918. In Spain, as in the Netherlands, admission came without legislation, although even under the republican government of the early 1930s Spanish women could only be private attorneys. [77]

In eastern Europe, the successor states of Estonia, Latvia, Lithuania, Poland, Czechoslovakia, and Yugoslavia all opened the legal profession to women by the end of 1920. In 1923 they were joined by Romania, where Ella Negrutzi became the first female attorney thirty-two years after Bilcesco's abortive attempt to register. [78] The two major holdouts in Europe were Bulgaria and Hungary. The former had women with legal degrees before 1910 but resisted opening the bar until after World War II. Hungary also barred female attorneys until after 1945, despite the fact that among Hungarian professionals in the interwar period, according to Maria Kov[acute{a}]cs, "the lawyers alone exhibited a stubborn attachment to their liberal traditions." [79]

When one examines the arguments made to justify the admission of women to the bar, especially in the early cases focused on individual women with law degrees, what is most striking is how little emphasis was placed on reasons why women should become lawyers. In large part, of course, this neglect reflected the primary concern with trying to demonstrate that women qualified as attorneys under existing law. For Po[ddot{e}]t, Popelin, and Chauvin, this strategy involved arguing that the Napoleonic statutes did not exclude women. They and their most vocal male supporters--Ferdinando Santoni-di Sio for Po[ddot{e}]t, Louis Frank for both Popelin and Chauvin--devoted much effort to countering claims that women could not be attorneys because these were de facto public officials, or might have to substitute for judges who were clearly officials. They also insisted that a married woman would not be required to obtain permission from her husband to take on each new client, violating confidentiality in the process. In a ddition, they asserted that laws or regulations granting women the right to earn degrees implicitly gave them the right to use those degrees. [80]

Kempin's arguments in court touched on some of these issues, but focused more directly on definitions of terms and rights in the Swiss national and the Zurich cantonal constitutions. In particular she highlighted occasions where the masculine term "B[ddot{u}]rger" applied to both sexes, asking provocatively if women did not have to pay taxes when the laws used only the masculine noun. She also insisted that women's explicit exclusion from the suffrage did not mean they lacked the rights of "active citizens." [81] As mentioned above, British women also struggled to demonstrate that they qualified as "persons" under existing law.

In a striking contrast to the United States, where court decisions admitted women to the bar in twenty-six states and the District of Columbia, such arguments never succeeded in European courts. [82] What ultimately proved decisive there were precedent and legislative intent, and on these issues alone women could not win. In Kempin's case, the Swiss Federal Court called her effort to expand the definition of "B[ddot{u}]rger" to be as "as new as it is audacious." In Popelin's case, the Court of Appeals in Brussels concluded, "The law that governs us, in accord with our customs ... and with the traditions of the past, does not permit women to exercise the profession of attorney before the tribunals." In blocking Margaret Hall from becoming a solicitor, a Scottish court appealed to "inveterate usage"; while in rejecting Gwyneth Bebb's appeal in 1913, Judge Lord Phillimore insisted that "long usage ought to govern the law." A French lawyer named Jean Signorel went so far as to say of the male monopoly of the bar , "What has eternally been a human institution cannot fail to be a divine institution." [83]

Outside the courts, defenders of women lawyers relied most heavily on arguments based on freedom of occupation. Santoni-di Sio concluded his lengthy essay in defense of Po[ddot{e}]t with the assertion that the Turin courts were guilty of "a despicable rape of freedom of occupation." Chauvin's dissertation began with the claim that "the principles of the liberty of the professions and the idea of equity" should decide the question of women's employment opportunities. In the French Chamber, Viviani defended Chauvin's rights with an appeal to the advocates of laissez-faire. Shortly after admission of French women to the bar, Belgian socialists led by Vandervelde proposed similar legislation based on the same claim. The Belgian attorney Henri LaFontaine backed this proposal, stating, "In favor of this admission, there is only a single argument, but a peremptory one: women have the right to exercise all professions for which they have established ... that they have the required abilities." At the turn of the cent ury, Austrian journalist Helena Migerka asked rhetorically, "Can a true Rechtsstaat exist where one half of the human race judges and litigates, determines and decides everything for itself and for the other half?" [84]

The injustice to the individual women also figured prominently in the writings of their supporters. Santoni-di Sio reported the views of several lawyers and professors who thought Po[ddot{e}]t should not have been denied the right to practice after completion of all her studies. Romeo Taverni, a professor of pedagogy at Padua, added the warning, "If society does not grant [qualified women] the right to exercise the professions, it runs the risk of creating more nihilists." In Belgium a lawyer named Goddyn, as well as a commission created in 1893 by the Order of Barristers at the Brussels Court of Appeals, pointed out the absurdity of allowing women to earn degrees that they could not use. When Emilie Kempin's second application to be a Privatdozentin at Zurich was considered by the university senate, medical professor August Forel argued in a similar fashion that there was "absolutely no valid reason to allow women to study and to forbid them to teach." In allowing Teresa Labriola to register as an attorney, the Council of the Order at Rome also noted that a woman who could teach law at the university ought to be able to practice it. [85]

Another prominent theme in arguments for admission of women involved claims that the laws needed to catch up with the times. Po[ddot{e}]t herself told the Turin Court of Appeals that the Attorney General's views of women were ones "that perhaps time and events can change." Santoni-di Sio argued that the principles of Roman law "had run their course, and the progress of the times, the changed customs, and the new political order, do not consent that they be invoked any more, except for archaeological ends." For Frank, the "mission of modern jurisprudence" was to "follow and second the incessant progress of ideas and customs." In England, a lawyer named Holford Knight pointed out, in defense of admitting women to the bar, that "the progressive extension of this test of fitness has been one of the outstanding marks of advancing civilization." [86]

Particularly in the early cases, proponents of female attorneys seldom based their arguments on any notions of special female talents for the law, such as Svetlin suggested, or on special needs that female attorneys could fill. Santonidi Sio's account of the Italian debates over Po[ddot{e}]t's case in 1883-84 contains not a single mention of such issues. [87] Both Frank's defense of Popelin and Chauvin's dissertation also omitted discussion of special talents and needs. In contrast to Bilcesco and Chauvin, Kempin did nor even devote her dissertation or other early writings to the "woman question"; she certainly did not base her case for admission to the bar on her ability to render special services to female clients. When Madame Potonie-Pierre spoke at a women's rights congress in Paris in 1889, she suggested that women lawyers would simply be more honest than men, replacing "our sly and crafty speechifiers, our experts in chicanery and dupery." [88]

In advance of the referendum in the canton of Zurich in 1898, however, nine women's organizations circulated a statement that spoke of "the great need for female attorneys." In the same year, Frank's defense of Chauvin included comments, not present in his earlier defense of Popelin, about the special contributions women could make in the legal profession. He cited Le Temps of Paris to the effect that women lawyers would eventually "modify or abrogate laws that, today, are the last refuge ... for the misconduct of men," a reference to the French law that prohibited paternity suits. He also cited an American official who suggested that women jurors were more likely than men to punish drunkenness, gambling, debauchery, and disorder. Frank himself added, "In the innumerable affairs of the morals police, of the protection of young girls, where the interests of the female sex are directly involved, the presence of a woman lawyer at the bar could only be very beneficial." [89]

Speaking at the International Congress of Women in London in 1899, Popelin combined the more common progressist view of women's right to practice law with a defense of the female attorney "as the natural confidant of the persons of her sex in litigious affairs, the indispensable auxiliary in feminine cases, where the motives of the accused can only be appreciated by her." During one of Chauvin's first court appearances in 1901, she too responded to favorable greetings from a judge by noting how "the cold and severe appearance of men of the law" sometimes scared off women who would prefer to "confide to another woman the secret of certain miseries, certain sorrows." Chauvin even suggested that it was a "completely feminine task to console those who suffer." In 1901 as well, the Belgian Henri LaFontaine argued that female attorneys "would impregnate [sic] the judicial spirit with pity and forgiveness; justice will thereby become more feminine, and thus more human." In England in 1913, Eleanor Rathbone noted ho w "many of the worst wrongs which women, and especially young girls, suffer never come to light because the victims cannot bring themselves to place their case and all its humiliating details before a man." Her colleague Lucy Nettleton added, "In divorce, especially, it is far easier for the woman to have at least the preliminary inquiries conducted by one of her own sex." [90]

Although comments such as these mirror what proved to be the most effective argument for opening the medical profession to women, that female physicians were necessary for treating girls and women, they never shaped the debate about female attorneys to a similar extent. [91] In part, this lesser emphasis reflected the smaller percentage of the female population who required legal as opposed to medical assistance, and perhaps the disreputable character of some of the women who did. Yet the pioneering women lawyers, by their training and often by their personal inclinations, tended to focus on equal rights rather than on a "relational" or "maternal" feminism that might have promoted notions of special talents or needs. What Leslie Howsam has said with regard to the English case could easily be applied to most of the pioneers: compared to female physicians, "the law graduates ... were determinedly individualistic and rigorously committed, as a consequence of their training, to an ideal of equality." [92]

As mentioned above, court decisions rejecting admission of women to the bar relied primarily on legislative intent and precedent. Even the court decisions, however, often revealed that much more than precedent was at stake. The Turin Court of Appeals, in rejecting Po[ddot{e}]t's bid to join the Order of Barristers, argued that pleading in court would be "contrary to the reserve and modesty appropriate to her sex." Women should not enter the "forensic arena" where they might have to deal with "questions that the rules of polite society prohibit from being discussed in the presence of respectable women." The judges also noted "the risk to the seriousness of the proceedings if one sees the 'toga' covering the strange and bizarre outfits that fashion often imposes on women, and hairdos no less bizarre" under the wigs of female attorneys. In addition, they expressed concern about "the very grave danger to which judges will be exposed of becoming objects of suspicion and calumny every time that the scales of justi ce tilt in favor of the party for whom a lovely woman lawyer has pleaded." In the case of Popelin as well, the Brussels Court of Appeals argued that "the particular nature of woman, the relative weakness of her constitution, her special mission for humanity, the demands and restrictions of motherhood, the education that she owes her children, the oversight of the home confided to her, all put her in conditions scarcely reconcilable with the duties of the profession of attorney, and give neither the leisure, the energy, nor the aptitudes needed for the struggles and toils of the bar." [93] In the wake of these extravagant statements, a supporter of Chauvin expressed relief that the French court had limited its rejection of her application strictly to matters of the law. [94]

The declarations by the courts in Turin and Brussels contain many of the points of view expressed by opponents of female attorneys. One of the most frequently used arguments was that practicing law would corrupt women. A Belgian lawyer named Dykmans insisted that it was because of "the respect to which a woman has a right that it is necessary to exclude her from the courtroom." For the French senator Gourju, admission of women to the bar would be a crime of "l[grave{e}]se-majesr[acute{e}] f[acute{e}]eminine." In England, a supporter of granting women access to the bar noted in 1911 that the only legitimate argument advanced by the opposition was "that the places where legal cases are held, namely the courts, are not fit for women to abide in, partly because of the physical and partly because of the moral atmosphere." 95

In some cases it is clear that opponents feared not only for the femininity of women lawyers, but also for their own masculinity. There is more than a little anxiety evident in the assertion by the distinguished Italian jurist Carlo Gabba that liberal individualism of the sort employed by Po[ddot{e}]t's defenders would lead to "an abstract type of human being, without nationality, history, or sex." German professor of law Otto Gierke claimed loudly that "men's professions must remain men's professions." Similar sentiments surfaced in The Spectator at the time of Bertha Cave's application to Gray's Inn. As the anonymous author put it, "The situation was simply one of those in which a community is brought face to face with elemental considerations, when it is forced to remember that a man is a man and a woman a woman." [96]

Perhaps the most sweeping catalog of the decadence associated with female attorneys came from the pen of a Belgian Redemptorist named Francis Xavier Godts. Writing shortly after France admitted women to the bar, Godts not only linked feminism to a long chain of events from the Protestant Reformation through the French Revolution to socialism, but he also blamed the Walloon element in Belgium for all feminist demands. France had recognized the need for female attorneys, Godts commented ironically, as it had the "need for divorce and free love, for pornography [acute{a}] la Zola and the immoral theater, for houses of prostitution, for commercial trusts, and for a thousand other infamies." [97]

Opponents not so concerned with the threat to femininity or to the social order still found reasons to reject female attorneys. One was that such women would not be discreet. An Englishman named Marcus Reed suggested that women would never be able to maintain the confidentiality expected of the "trusted family solicitor." He also asked, "What guarantee have we that the time of the Court would not be scandalously wasted by unending arguments not bearing in the least on the question at issue? The feminine mind has a tendency that way." The French antifeminist Charles Turgeon expressed similar views soon after Chauvin's admission to the bar. [98]

Another frequent claim by opponents was that women should not be lawyers because they thought with their hearts, nor their heads. Kempin informed colleagues in the United States, "When I began to turn my knowledge to practical account, then they [her detractors] cried out that it was impossible for a frail woman to reason logically." A Belgian lawyer named Lacombl[grave{e}] insisted that "woman lacks the spirit of synthesis; she does not have the general notions that are necessary to reasoning." In Italy as well, there were frequent assertions that women lacked "reason, logic, and a sense of equilibrium." In 1913, at the height of debate about English women becoming solicitors, one barrister claimed that "in women emotional feelings would be prone to be roused to the detriment of pure justice." Another English lawyer suggested that "women have no idea of relevance, or analogy, or evidence." [99]

Closely related to these notions of women being ruled by emotion was a common perception that they could not be impartial. In 1868, before any women had pressed for admission to the bar, a Swiss writer named Julius Caduff challenged their capacity on this ground, noting how the traditional female figure of justice was blindfolded. With her eyes open, Caduff asserted, she would judge by appearances. A Belgian lawyer named Destr[acute{e}]e agreed, claiming that women judged "by minor details, by the exterior." In France, according to Turgeon, "We do not have the least confidence in the spirit of justice of women." In England during the war, Lord Halsbury asserted, "Cool judgment and the absence of partisanship were qualities which a solicitor ought to possess ... and those qualities were not commonly found in woman." He also insisted that "a woman had no recognition of any side but her own." [100]

In Germany, where so many lawyers found employment in courts of various types, a more frequent assertion was that women judges would be soft on crime. Law professor Paul Laband argued in 1897 that women were too weak "to wield the sword of justice." After the war, the professional associations of both judges and lawyers made similar claims. Even a supporter of opening the legal profession to women, writing in 1919 in a leading feminist journal, commented that there was no guarantee that a woman judge would not "be too strongly influenced by her feelings of sympathy for the accused." [101]

In many countries, lawyers objected to opening their profession to women by claiming that it was already overcrowded. Whatever credence one gives to such claims, which in most cases were transparently self-serving, [102] they do reveal an underlying belief that women could and would succeed as attorneys. As early as 1884, the radical physician Agostino Bertani, commenting on the decision in Poet's case by the Turin Court of Appeals, suggested that the true concern was not with women wearing ridiculous outfits under their togas but with "seeing an increase in the number of togas." Over the years, however, evidence from the United States demonstrated to all willing to learn from it that the number of women choosing to enter the legal profession would remain small. Around the turn of the century, commentators in France, Belgium, Switzerland, and England all pointed out that concerns about female attorneys seriously aggravating the overcrowding of the profession were a smokescreen. [103]

Yet male lawyers did fear female competition. One of the few willing to grant that women might possess intellectual skills, Marcus Reed, nonetheless turned this admission into a joke by noting, "Few men, queer creatures that they are, would care to marry a King's Counsel famous for her skill and success in cross examination." More common were fears, like those expressed by the judges in Turin, that women would triumph in court through their looks. At the time of Po[ddot{e}]t's case, Italian jurist Alberto Marghieri warned that female attorneys would have "a powerful influence on the minds of judges, and not always in the interest of truth." In Popelin's case as well, opponents stressed "the dangers of corruption of the judiciary" that women in the courtroom would pose. In discussions in the Middle Temple in 1919, a King's Counsel described as "able but very plain" asked, "What chance should I have with a jury against a fair and pleasing pleader?" [104] Such arguments assumed particular prominence in France i n the late 1890s as the legislature moved toward opening the bar to women. The most famous expression of this anxiety about women unfairly influencing judges and juries was Adolphe Willette's cartoon of Jeanne Chauvin opening her robe to reveal her "last and best evidence"--her breasts. [105]

Whether more concerned about the skill or the wiles of their potential female adversaries, many opponents clearly feared that admission of women to the legal profession would lead directly--and swiftly--to suffrage and other forms of civic equality for women. Such views were particularly widespread in Germany and Austria, where the law was so closely tied to the civil service. According to Ludwig von Bar, a law professor at the University of G[ddot{o}]ttingen, "If women function publicly as attorneys and judges, it will be impossible to withhold political rights from them for very long." The same point was made in the Prussian Ministry of State in 1905 by Arthur von Posadowsky, who several years earlier had been a central figure in opening the medical profession to German women. In 1913, Erna von Langsdorff, one of the first generation of German women with a law degree, observed that opponents of opening the bar believed that "as soon as women exercise judicial functions, the collapse of the masculine state will be imminent." For Austrian professor of law Ludwig Wahrmund, admission of women to the bar would, in fact, "ensure the definitive success of the women's movement." [106]

For the many lawyers in the Italian and French legislatures, who knew how training in law led to political careers if not necessarily to civil service positions, admission of women to the bar could also appear as an irrevocable step toward full equality. During the debate on Viviani's bill in the French Chamber in 1899, the Comte de Lanjuinais suggested that the deputies might as well "go all the way and demand the right to vote for women." More surprising, such views surfaced in Zurich, where the bar was not even a closed corporation. In February 1892, a law professor named Treichler, about to have Kempin join him on the faculty, wrote in the Z[ddot{u}]rcher Post, "If women are allowed to be attorneys, that will have the consequence that women will have to be made equal to men in all areas." [107]

The grand irony in this matter is the inaccuracy of these perceptions of a direct link between opening the legal profession and suffrage. [108] Finland, Norway, and Denmark stand out as the only countries where women's suffrage followed closely on the heels of their admission to the bar, taking place between 1906 and 1915. The Netherlands and Sweden, also pioneers in opening the legal profession, did not approve votes for women until after World War I (in which neither took part). In England, Germany, Austria, Russia, and most of the successor states, suffrage preceded admission to the bar in the immediate postwar years. Italy, Belgium, Spain, Portugal, Rumania, and Yugoslavia opened the bar at that time without granting suffrage, which came to Spain and Portugal (with strict limitations) in 1931, to the other four countries only after World War II. Hungary opened suffrage--intermittently--after independence without opening the bar; Bulgaria delayed both votes and legal practice for women until after 1945. M ost striking are the cases of France and Switzerland. In the former, the same Chamber that in 1899 voted 319-174 in favor of admitting women to the bar chose two years later to bury a suffrage bill in a committee from which it never reemerged. [109] French women did not win the vote until 1945. Swiss women, who gained access to the bar between 1898 and 1923, could not participate in national elections until 1971.

Where does this survey of the processes by which women entered the legal profession and of the arguments used to justify or oppose this innovation take us in answering the questions posed at the outset? With regard to the priority of admission to medicine over admission to law, these fears about the anticipated consequences of access to the bar, despite their inaccuracy, provide an important clue. However "unnatural" many contemporaries considered women who studied anatomy and venereal disease to be, few viewed admission of women to medicine as leading so directly to other rights, especially not to suffrage. That the central arguments for admission to the bar rested so squarely on equal rights, freedom of occupation, and "progress" highlighted the link between this reform and what Ludwig Wahrmund called "the definitive success of the women's movement." It was thus not so much the public functioning of women lawyers as the arguments used on their behalf that roused the most adamant opposition, especially from government officials. Of the possible explanations for the delay in opening the bar mentioned at the beginning of the essay, that of Gidney and Millar appears most generally applicable. [110]

The relative lack of attention to what female attorneys could do for other women or for society as a whole also explains, at least in part, another aspect of the lag in opening the legal profession: the comparatively low level of attention devoted to this issue by organized women's movements. Pioneers such as Po[ddot{e}]t, Kempin, and Popelin, especially when their court cases first arose, were what Geraldine Joncich Clifford has called, in another context, "lone voyagers." [111] In 1873, Eliza Orme had the support of the Women's Education Union in attempting to gain entrance to lectures at Lincoln's Inn, but that support faded; by the 1920s Orme had become a "non-person" in the history of women's rights in England. [112]

Universities clearly did not present the major stumbling block to entering the legal profession. Anna Evreinova in Germany; Fanny Berlin and Emilie Kempin-Spyri in Switzerland; Lidia Po[ddot{e}]t in Italy, Eliza Orme, Letitia Walkington, Frances Grey, and Cornelia Sorabji in the United Kingdom, Marie Popelin in Belgium, Sarmisa Bilcesco and Jeanne Chauvin in France--all completed their legal studies without major incident by 1892 (and all but Sorabji with a degree). More telling, Kempin at Zurich, Elisabeth van Dorp at Utrecht, and Teresa Labriola at Rome held university lectureships before they could practice law in their own countries; Elsa Eschelsson at Upsala chose a lectureship over practice. All four received their appointments before any equivalent female pioneers began teaching in the medical faculties of their nations' universities. Where women had the most difficulty gaining access to legal studies--in the Russian, Austro-Hungarian, and German empires--central governments rather than university fac ulties proved to be the greatest obstacles. From the perspective of higher education, it is difficult to see medicine as a more "natural" field for women than law.

If entering practice was the crucial hurdle, does Robert Stevens' observation that the "legal profession was institutionalized ... earlier than the medical profession" offer a convincing general explanation? That Sweden, Finland, and the canton of Zurich, areas where the bar was not a closed corporation, saw female physicians before attorneys suggests institutionalization is not a complete answer. The newly created bar in Russia proved no more welcome to women than the much older one of England or the newly reorganized one in Germany.

More intriguing, in fact, is the frequency with which local groups of lawyers welcomed women into their ranks, only to have their actions overturned. Po[ddot{e}] in Turin, Bilcesco in Bucharest, Labriola in Rome, Russian women wanting to be private advocates in the 1870s, other Russian women trying to become sworn advocates in training in 1908, even Maria Schmidbaur-Droste in Bavaria--all at first succeeded in entering their names on official registers of the legal profession. Other women blocked from registering--Poplein, Chauvin, Bertha Cave, Margaret Hall--had their male supporters. Many of the women who could not, or did not try to, register--Orme, Po[ddot{e}]t, Popelin, Nana Berg--found attorneys willing to employ their services.

In the case of law, Anne Witz's thesis that "the nineteenth-century patriarchal capitalist state was the weakest link in the chain of patriarchal closure" does not hold true. The opposite appears more accurate: as Ruth Dudgeon wrote about Tsarist Russia, "it was, first and foremost, the opposition of the state which prevented these women students from achieving their professional goals." [113] Such opposition was most blatant in Russia, with the interventions of Alexander II in 1876 and the Empress Alexandra during World War I. Yet in most countries, government ministries, attorneys general, and judges provided the crucial obstacles for women trying to become attorneys. Such officials often did act in accord with the wishes of the majority of the legal profession. Without their actions, however, support from a select minority of lawyers would have enabled women in several countries to begin practice. That legislatures and ministries did eventually override the continuing opposition of most male practitioners and admit women to the bar does not vitiate this point. Given the series of court decisions stating that women did not qualify as attorneys under existing law, the only pathway to change was legislation. In light of the long delays between negative court decisions and new laws in countries such as Italy and Belgium, however, the state does not appear as a particularly "weak link" in defense of male privilege.

Such legislative actions bring us to the second broad question posed at the outset, whether there is a consistent explanation for the different timing of the opening the bar in the various countries. The answer appears to be "no." As with so many issues related to the history of women's educational and employment opportunities, no direct connection emerges between levels of "modernization" -- however defined--and admission of women to the legal profession. That England, Germany, Portugal, and Russia allowed women to become lawyers at virtually the same time undermines any general interpretation based on economic development or liberal political traditions. That those countries or cantons without a corporate bar were among the first to allow women to plead in court indicates that the lack of institutionalization of the legal profession helped accelerate the admission of women. Yet other pioneers such as France and the Netherlands had tighter regulations for the practice of law, in the case of France a system virtually identical to that of the laggards Belgium and Italy.

The early opening of the bar in the Netherlands and the Scandinavian countries suggests that Protestant countries demonstrated greater openness to female attorneys than did Catholic ones, a theme ignored in Ilse Costas' discussions of this issue. [114] Yet England and Germany stand out as major exceptions to this pattern on the Protestant side, France on the Catholic. The factors Costas employs to explain French priority over Germany certainly do little to explain its priority over England, which had a democratic tradition, a legal profession not tied to the civil service, a diverse system of higher and professional education, and less concern with overcrowded professions than did France. Neither does French anti-clericalism alone explain its exceptional position among Catholic countries. The French Chamber at the turn of the century contained many more clerical conservatives that did the Italian, in which pious Catholics refused to take part. As the deputy Massabuau noted at the time, the best explanation f or the law opening the French bar to women was that it served the interests of one person, Jeanne Chauvin. [115]

In 1906, Pope Pius X made clear in an interview that he supported allowing women to become physicians and lawyers, but not electors or deputies. [116] While the direct influence of this statement is difficult to trace, developments in Italy, Belgium, Spain, and Portugal in the late 1910s and early 1920s did reflect papal sentiments. Why Belgian Catholics opposed female attorneys in 1912 but approved them a decade later, however, is not clear. Unclear as well is why Teresa Labriola, who probably had better political connections through her father than did Chauvin through her brother, did not win parliamentary support in Italy before the war.

In many ways, the widespread opening of the legal profession at the end of World War I has the appearance of a bandwagon effect, among the nonbelligerent as well as the belligerent powers. By that time, of course, evidence from pioneering European countries as well as the United States had demonstrated that opening the bar to women would not produce a flood of female attorneys. In the defeated empires, the overthrow of the monarchical regimes and the introduction of women's suffrage preceded the opening of the bar; but Hungary did not follow this pattern. Social Democrats played important roles in introducing legislation in Germany, Austria, and Belgium, but not in England, Italy, or Romania. As previously noted, support for female attorneys came from all parties in Belgium in 1922, although Catholic conservatives had previously opposed their admission to the bar in 1890 and 1912.

It is clear that no single factor, or simple combination of factors, comes close to explaining the timing of the opening of the legal profession to women in the various European countries. At the distance of a century from the Zurich referendum of 1898, in fact, what is most striking is the relative simultaneity of the process in countries with widely differing economic, social, political, religious, and professional traditions. In the quarter century between the Zurich referendum and the court case that extended this victory to all of Switzerland in 1923, women gained access to the bar in almost all of Europe. This time span was somewhat shorter than that required for the opening of certified medical practice to women in these countries, significantly shorter than that required for the universal introduction of women's suffrage. It was approximately half as long as the forty-four-year gap between the admission of women to the bar in the Canadian provinces of Ontario (1897) and Quebec (1941), less than half the fifty-four year gap between Iowa (1869) and Delaware (1923). [117]

Pioneers did not, of course, always retain their positions. As noted above, Germany had female judges several decades before France or Switzerland, even though it opened its legal profession twenty years later; yet during the Third Reich women virtually disappeared from the justice system. In Protestant Scotland, the first woman gained access to the bar in 1923, shortly after Ivy Williams did so in England; but Scotland's second female barrister did not appear until 1949, putting that country far behind most of Europe. [118] After Emilie Kempin earned her doctorate in law in 1887, no other Swiss woman did so at the University of Zurich until 1912. More remarkable, Kempin, who in 1892 became the first woman to lecture in law at a European university, did not have a female successor at the University of Zurich until 1983. [119]

ENDNOTES

(1.) Wilhelm Svetlin, Die Frauenfrage und der [ddot{a}]rztliche Beruf (Leipzig and Vienna, 1895), pp. 10-11. On 25 April 1895, the Neues Wiener Tageblatt editorialized that the courtroom was "a place where women belonged just as little as they did in anatomy lectures"; see Marina Tichy, "Zur Geschichte des rechtswissenschaftlichen Studiums von Frauen: Die juridische Fakul[ddot{a}]t Wien his zum Ende der Ersten Republik," in Bildungswesen und Sozialstruktur in Mitteleuropa im 19. und 20. Jahrhundert, ed. Victor Karady and Wolfgang Mitter (Cologne and Vienna, 1990), p. 278.

(2.) This Hungarian peculiarity is not mentioned in recent works by Maria Kov[acute{a}]cs: The Politics of the Legal Profession in Interwar Hungary (New York, 1987); "Hungarian Women Entering the Professions: Feminist Pressures from Left and Right," in Bildungswesen und Sozialstruktur, ed. Karady and Mitter, pp. 247-57; Liberal Professions, Illiberal Politics: Hungary from the Habsburgs to the Holocaust (Oxford, 1994).

(3.) Relevant here are Margarete Freiin von Erffa and Ingeborg Richarz-Simon, "Der weibliche Rechtsanwalt," in Die Rechtsanwaltschaft, ed. Julius Magnus (Leipzig, 1929), pp. 471-85; Edm[acute{e}]e Charrier, L'[acute{e}]volution intellectuelle f[acute{e}]rninine (Paris, 1931); Piero Addeo, Eva togata (Naples, 1939); and Zara Algardi, La donna e la toga (Milan, 1949).

(4.) There is, for example, no mention of women lawyers in Bonnie S. Anderson and Judith P. Zinsser, A History of Their Own: Women in Europe from Prehistory to the Present, vol. 2 (New York, 1988). The one mention of a woman lawyer, the Swiss Emilie Kempin-Spyri, in Genevi[acute{e}]ve Fraisse and Michelle Perrot, eds., A History of Women in the West, Vol 4: Emerging Feminism from Revolution to World War (Cambridge, Mass., and London, 1993), contains several errors: see Anne-Marie K[ddot{a}]ippeli, "Feminist Scenes," p. 509.

(5.) Thomas N. Bonner, To the Ends of the Earth: Women's Search for Education in Medicine (Cambridge, Mass., and London, 1992).

(6.) See, for example, Brian L. Levin-Stankovich, "The Transfer of Legal Technology and Culture: Law Professionals in Tsarist Russia," in Russia's Missing Middle Class, ed. Harley Balzer (Armonk, New York, and London, 1995), pp. 223-49; and Kenneth Led-ford, "Conflict within the Legal Profession: Simultaneous Admission and the German Bar, 1903-1927," in German Professions, 1800-1950, ed. Geoffrey Cocks and Konrad Jarausch (New York and Oxford, 1990), pp. 252-69. The admission of women to the legal profession in various countries receives brief and inconsistent coverage in Richard L Abel and Philip S. C. Lewis, eds., Lawyers in Society, 3 vols. (Berkeley, Los Angeles, and London, 1988-89).

(7.) Hannes Siegrist, Advokat, B[ddot{u}]rger und Stoat: Sozialgeschichte der Rechtsanw[ddot{a}]lte in Deutschland, Italien und der Schweiz (18.-20. Jahrhundert), 2 vols. (Frankfurt am Main, 1996). Siegrist did not use Charrier, Addeo, or Algardi, mentioned in note 3 above.

(8.) Peter Gay, The Cultivation of Hatred (New York and London, 1993), p. 363; Barbara Harris, Beyond Her Sphere: Women and the Professions in American History (Westport, Conn., 1978), p. 110; R. D. Gidney and W. P. J. Millar, Professional Gentlemen: The Professions in Nineteenth-Century Ontario (Toronto, Buffalo, and London, 1994), p. 325.

(9.) Nellie Alden Franz, British Women Enter the Professions (Cincinnati, 1965), p. 277; Leslie Howsam, "'Sound-Minded Women': Eliza Orme and the Study and Practice of Law in Late Victorian England," Atlantis 15, no. I (Fall 1989): 47; W. J. Reader, Professional Men: The Rise of the Professional Classes in Nineteenth-Century England (London, 1966), p. 18. A view similar to that of Franz can be found in Michael Grossberg, "Institutionalizing Masculinity: The Law as a Masculine Profession," in Meanings for Manhood: Constructions of Masculinity in Victorian America, ed. Mark Carnes and Clyde Griffin (Chicago, 1990), pp. 133-51.

(10.) E. Sylvia Pankhurst, The Suffragette Movement: An Intimate Account of Persons and Ideals (London, 1931), pp. 179, 214.

(11.) Reader, Professional Men, p. 174.

(12.) Arthur Kirchhoff, ed., Die akademische Frau (Berlin, 1897). This imbalance stemmed in part from the fact that opening the medical profession was a more likely prospect at the time.

(13.) Aletta Jacobs Gerritsen was, of course, a physician.

(14.) JoManton, Elizabeth Garrett Anderson (New York, 1965), pp. 104-108; Edith Lutzker, Women Gain a Place in Medicine (New York, 1969), p. 75; Franziska Tiburtius, Erinnerungen einer Achtzigj[ddot{a}]hrigen, 2d ed. (Berlin, 1925), p. 107; Charrier, L'[acute{e}]volution, p.442 Bonner, To the Ends of the Earth, pp. 71-73.

(15.) Simonetra Ulivieri, "La donna e gli studi universirari nell'ltalia postunitaria," in Cento anni universit[grave{a}], ed. Francesco De Vivo and Giovanni Genovese (Parma, 1986), p. 225; James C. Albisetti, Schooling German Girls and Women (Princeton, 1988), p. 236; Kov[acute{a}]cs, "Hungarian Women," pp. 251-52.

(16.) Boucherett cited in Howsam, "'Sound-Minded Women,"' p. 47; Pankhurst, The Suffragette Movement, p. 214; Christine Bard, Les filles de Marianne: Histoire des f[acute{e}]minismes, 1914-1940 (Paris, 1995), p. 178. Steven Hause characterizes the incident with Chauvin as a "riot," but this seems exaggerated: Hause, with Anne R. Kenney, Women's Suffrage and Social Politics in the French Third Republic (Princeton, 1984), p. 24.

(17.) Virginia Drachman, Sisters in Law: Women Lawyers in Modern American History (Cambridge, Mass., 1998), pp. 56, 74.

(18.) Drachmann, Sisters in Law; Karen Berger Morello, The Invisible Bar: The Woman Lawyer in America, 1638 to the Present (Boston, 1986); Constance Backhouse, Petticoats and Prejudice: Women and Law in Nineteenth-Century Canada (Toronto, 1991), p. 293.

(19.) Robert Stevens, Law School: Legal Education in America from the 1850s to the 1980s (Chapel Hill, 1983), p. 82; Anne Witz, Professions and Patriarchy (London, 1992), p. 103; Richard Abel, "Lawyers in the Civil Law World," in Lawyers in Society, ed. Abel and Lewis, 2: 35.

(20.) Ilse Costas, "Der Kampf um das Frauenstudium im internationalen Vergleich," in Pionierinnen, Feministinnen, Karrierefrauen? Zur Geschichte des Frauenstudiums in Deutschland, ed. Anne Schl[ddot{u}]ter (Pfaffenweiler, 1992), pp. 115-43; idem, "Das Verh[ddot{a}]ltnis von Profession, Professionalisierung und Geschlecht in historisch vergleichender Perspektive," in Profession und Geschlecht: [ddot{U}]ber die Marginalit[ddot{a}]t von Frauen in hochqualifizierten Berufen, ed. Angelika Wetterer (Frankfurt and New York, 1992), pp. 51-82; idem, "Der Zugang von Frauen zu akademischen Karrieren: Ein internationaler [ddot{U}]berlick," in Bedrohlich gescheit: Ein Jahrhundert Frauen und Wissenschaft in Bayern, ed. Hiltrud H[ddot{a}]ntschel and Hadumod Bussmann (Munich 1997), pp. 15-34; and, most focused on law, idem, "Gesellschaftliche Umbr[ddot{u}]che und das Verh[ddot{a}]ltnis von Profession und Geschlecht: Die juristische Profession im deutsch-franz[ddot{o}]sischen Vergleich," in Das soziale Konstruktion von Geschl echt in Professionalisierungsprozessen, ed. Angelika Wetterer (Frankfurt and New York, 1995), pp. 121-38.

(21.) The indispensable source for Po[ddot{e}]t's case is Ferdinando Santoni-di Sio, La donna e l'avvocatura (Rome, 1884). A brief modern treatment can be found in Marino Raichich, "Liceo, universit[grave{a}], professioni: un percorso difficile," in L'educazione delle donne: Scuole e modelli di vita femminile nell'Italia dell'Ottocento, ed. Simonetta Soldani (Milan, 1989), pp. 15 1-53. For the general context, see Maria Malatesta, ed., Society and the Professions in Italy, trans. Adrian Belton (Cambridge, 1995).

(22.) Algardi, La donna e la toga, p. 25. Emile de Laveleye refers to a woman receiving a degree in 1881 from Bologna, but I believe he refers to Poe[ddot{e}]t at Turin: "L'instruction sup[acute{e}]rieure des femmes," in Essais et [acute{e}]tudes (3 vols.; Ghent and Paris, 1894), 2: 359.

(23.) See Cahiers f[acute{e}]ministes, 5, no. 13 (1 Sept. 1900).

(24.) Addeo, Eva togata, p. 142; Pietro Cogliolo, "Le donne avvocate secondo ii diritto italiano: difesa per Teresa Labriola," in Scritti varii di diritto privato, 2 vols. (Turin, 1917), 2: 64; Florenza Taricone, Teresa Labriola: Biografia politica di un'inrelletuale tra Ottocento e Novacento (Milan, 1994), pp. 14-19. It is not clear why Labriola suddenly decided to apply for admission to the bar more than a decade after her degree. She would later be a strong advocate of Italian intervention in World War I and a supporter of Fascism.

(25.) Maria Malatesta, "The Italian Professions from a Comparative Perspective," in Society and the Professions, ed. Malatesra, p. 15; Marco Santoro, "Officials and Professionals: Notaries, the State, and the Market Principle," ibid., pp. 111-14; Michela DeGiorgio, Le Italiane da1l'unit[grave{a}] a oggi (Rome and Bari, 1992), p. 483.

(26.) Francoise de Bueger-van Lierde, "Marie Popelin," in Biographie nationale de Belgique 39 (1976), col. 733-42; idem, "A l'origine du mouvement f[grave{e}]ministe en Belgique: 'L'Affaire Popelin,'" Revue beige de philologie et d'histoire 50 (1972): 1,128-37; idem, "Marie Popelin et les d[acute{e}]buts du mouvement f[acute{e}]ministe belge (1892-1914)," in Femmes des ann[acute{e}]es 80: Un si[acute{e}]cle de condition f[acute{e}]minine en Belgique, 1889-1989, ed. Luc Courtois et al. (Louvain-la-Neuve, 1989), pp. 197-202. Popelin is described as having a licence rather than a doctorate in Moisei Iskovelevich Ostrogorskii, The Rights of Women (London, 1893), p. 144.

(27.) Louis Frank, La femme-avocat: Expos[acute{e}] historique et juridique de la question (Paris, 1898), pp. 71-83, quotation on p. 81. Frank had published a shorter work under the same title in Brussels in 1888, before Popelin's case went to court. The new version, not identified as a second edition, appeared in defense of Jeanne Chauvin's claims in France. These works will be referred to as Frank (I) and (11).

(28.) Cited in Marthe Bo[ddot{e}] and Christiane Duchene, Lef[acute{e}]minisme en Belgique, 1892-1914 (Brussels, 1955), p. 128.

(29.) De Bueger-van Lierde, "A l'origine," p. 1,137; Chattier, L'[acute{e}]olution p. 438; Addeo, Eva togata, p. 143; Luc Huyse, "Legal Experts in Belgium," in Lawyers in Society, ed. Abel and Lewis, 2: 231-33.

(30.) H. Barth[acute{e}]lemy, "Nos Grandes [acute{E}]coles: L'[acute{E}]cole du droit," Revue des deux mondes 36 (Nov.-Dec. 1926): 329-30; Frank, Lafemme avocat (I), p. 24; idem, Lafemme avocat (II), p. 120; Chattier, L'[acute{e}]volution, pp. 472-73. Bilcesco's dissertation was De la condition le[acute{e}]gale de la m[grave{e}]re (Paris, 1890).

(31.) "Jeanne Chauvin," Dictionnaire de biographie francaise, vol. 8 (Paris, 1959), p. 927; Jeanne Chauvin, [acute{E}]tude historique sur les professions accessibles oux femmes (Paris, 1892); Charrier, L'[acute{e}]vo1ution, pp. 336-38. There is no entry for Chauvin in Patrick Hutton, ed., Historical Dictionary of the Third French Republic, 1870-1940, 2 vols. (Westport, Conn., 1986).

(32.) Hause, Women's Suffrage, p. 122. Costas ignores both the specific political context and the presence of Chauvin's brother in the Chamber: see Costas, "Gesellschaftliche Umbr[dodot{u}]che".

(33.) France, Chamber of Deputies, D[acute{e}]bats parlementaries, 6th Legislature, 1898, pp. 1,338, 2,232-33; ibid., 7th Legislature, 1899, pp. 1,758-64; Cahiers f[acute{e}]ministes 5, no. 18(15 Nov. 1900); Christophe Charle, Social History of France in the Nineteenth Century, trans. Miriam Kochan (Oxford and Providence, 1994), p. 169. Charle, without benefit of international comparisons, suggests that worries about overcrowding led the French bar to institute "maximum limitations on entry by women': ibid., p. 177. Costas seriously underestimates French concern with overcrowding.

(34.) Chaiers f[acute{e}]ministes 5, no.22 (15 Jan. 1901); Hause, Women's Suffrage, p.53; Bard, Les filles de Marianne, p. 363 and passim. Bard also notes complaints about the fact that forty out of forty-four women lawyers registered in Paris as of 1917 were either foreigners or Jews: ibid., p. 405.

(35.) Costas, "Gesellschaftliche Umbr[ddot{u}]ache," p. 130; L. N. Brown, "The Office of the Notary in France," international and Comparative Law Quarterly 2 (1953): 62.

(36.) Jan Marinus Meijer, Knowledge and Revolution: The Russian Colony in Zurich (Assen, 1955), pp. 54, 208, 50; Marianne Delfosse, Emilie Kempin-Spyri (Zurich, 1994), p. 29; Pietro Scandola, ed., Hachschulgeschichte Berns (Bern, 1984), p. 500; Bonner, To the Ends of the Earth, p. 65. Both Delfosse and Scandola note Fanny Berlin's law degree, though neither is aware of her medical study and career. According to Laveleye, a Russian woman who earned a law degree in Bern in 1878 planned to open a legal advice office in St. Petersburg: "L'instruction sup[acute{e}]rieure," p. 358. That the same woman earned both degrees is not entirely certain, but the surgeon Fanny Berlin did not arrive in Boston until 1879: see Virginia Drachman, Hospital with a Heart: Women Doctors and the Paradox of Separatism at the New England Hospital, 1862-1969 (Ithaca and London, 1984), p. 107.

(37.) On Kempin, see Verena Stadler-Labhart, "Erste Studentinnen der Rechts- und Staatswissenschaften in Z[ddot{u}]rich," Z[ddot{u}]rcher Taschenbuch f[ddot{u}]r das Jahr 1981 (Zurich, 1981), pp. 74-112; Susanna Woodtli, Gleichberechtigung: Der Kampf urn die politischen Rechte der Frau in der Schweiz (Frauenfeld, 1983), pp. 93-98; Sabine Streiter, "Die Rechts- und Staatswissenschaftliche Fakult[ddot{a}]t," in Ebenso neu als k[ddot{u}]hn: 120 Jahre Frauenstudium an der Universit[ddot{a}]t Z[ddot{u}]rich, ed. Verein feministische Wissenschaft Schweiz (Zurich, 1988), pp. 177-84; Eveline Hasler, Die Wachsfl{ddot{u}]gelfrau: Die Geschichte der Emily Kempin-Spyri (Zurich, 1991; 11th printing, 1993), esp. p. 167; Delfosse, Emilie Kempin-Spyri; Christiane Berneike, Die Frauenfrage ist Rechtsfrage; Die Juristinnen der deutschen Frauenbewegung und das Buirgerliche Gesetzbuch (Baden-Baden, 1995).

(38.) Siegrist, Advokat, 432-34. Louis Frank incorrectly referred to Kempin as a "stagiaire," when there was no such apprenticeship in Zurich: La femme-avacat (1), pp. 32-33. See Kempin's own description of her activities in a letter to the American Equity Club in 1888, cited in Virginia Drachman, Women Lawyers and the Origins of Professional Identity in America: The Letters of the Equity Club, 1887-1890 (Ann Arbor, 1993), pp. 104-06.

(39.) Delfosse, Emilie Kempin-Spyri, pp. 39-43, 67-70, appendix 1; Hasler, Die Wachsfl[ddot{u}]gelfrau, pp. 228-35.

(40.) Morello, Invisible Bar, pp. 76-80. Drachman turns Kempin from Swiss to Belgian and mistakenly says that she left New York for a teaching position at Bern, which in fact never came to pass: Women Lawyers, pp. 281-83.

(41.) Streiter, "Die Rechts- und Staatswissenschaftliche Fakult[ddot{a}]t," p. 178; Delfosse, Emilie Kempin-Spyri, pp. 10-11,49-53.

(42.) Delfosse has discovered significant new material about her mental illness: Emilie Kempin-Spyri, pp. 16-22.

(43.) Ibid., pp. 55-66; Stadler-Labhart, "Erste Studentinnen," pp. 105-06. On Mackenroth see Gabi Einsele, "'Kein Vaterland': Deutsche Studentinnen in Z[ddot{u}]rcher Exil," in Pionierinnen, ed. Schl[ddot{u}]ter, p. 15.

(44.) Delfosse, Emilie Kempin-Spyri, pp. 47-48; Streiter, "Die Rechts- und Staatswissenschaftliche Fakult[ddot{a}]t," p. 178.

(45.) Leslie Howsam, "Eliza Orme," in Dictionary of National Biography: Missing Persons (Oxford, 1993), PP. 505-06; Howsam, "'Sound-Minded Women,"' PP. 45-49, quotations on p.46; J. H. Baker, "University College and Legal Education, 1826-1976," Current Legal Problems 30 (1977): 7. Baker, as welt as several other sources, incorrectly state that no woman got a law degree from London until 1917.

(46.) Michael Birks, Gentlemen of the Law (London, 1960), p. 276; Richard L. Abel, The Legal Profession in England and Wales (Oxford, 1988), p. 173; letter of Jessie Wright, 13 April 1888, printed in Drachman, Women Lawyers, pp. 142-45. Orme may have meant, of course, that she had not tried to become a barrister.

(47.) Frank, La femme-avocat (11), pp. 66-67; William A. W. Jarvis, "Cornelia Sorabji," Dictionary of National Biography, 1951-1960 (Oxford, 1971), pp.907-09. Sorabji returned to India to help women in purdah who could not consult male lawyers.

(48.) W. C. Richardson, A History of the Inns of Court (Baton Rouge, 1976), p. 355; Elsie Lang, British Women in the Twentieth Century (London, 1929), pp. 145-46; Hazel Fox, "Ivy Williams," Dictionary of National Biography, 1961-1970 (Oxford, 1981), pp. 1,081-82.

(49.) Birks, Gentlemen of the Law, pp. 276-77; Lang, British Women, pp. 146-50, 158, 164.

(50.) Charrier, L'[acute{a}]volution, p.457 Fox, "Ivy Williams," p. 1,081; Jarvis, "Cornelia Sorabji," p. 908.

(51.) On the Russian system, see Levin-Stankevich, "The Transfer of Legal Technology"; and Eugene Huskey, Russian Lawyers and the Soviet State: The Origins and Development of the Soviet Bar, 1917-1939 (Princeton, 1986), pp. 12-26.

(52.) The clearest account is in Ruth Arlene Fluck Dudgeon, "Women and Higher Education in Russia, 1855-1905," (Ph. D. diss., George Washington University, 1975), pp. 161-66. See also Marie Zebrikoff, "Russia," in The Woman Question in Europe, ed. Theodore Stanton (New York, 1884), p. 417; and Ostrogorskii, The Rights of Women, p. 155. Dudgeon calls the private advocates "solicitors," which is not the term employed by the sources cited in note 51.

(53.) Renate Drucker, "Zur Vorgeschichte des Frauenstudiums an der Universit[ddot{a}]t Leipzig," in Vom Mittelalter zur Neuzeit, ed. Hellmut Kretschmar (Berlin, 1956), p. 280. Drucker germanizes the spelling. Dudgeon mentions a second Russian woman, F. M. Kaufmann, with a foreign law degree in the 1870s; but I have been unable to trace her: "Women and Higher Education," p. 166.

(54.) Dudgeon, "Women and Higher Education," pp. 166-67; Frank, La femme-avocat (II), p. xvii; Erffa and Richarz-Simon, "Der weibliche Rechstanwalt," p. 479.

(55.) Linda Edmondson, Feminism in Russia, 1900-1917 (Stanford, 1983), pp. 147-48; Richard Stites, The Women's Liberation Movement in Russia: Feminism, Nihiusm, and Bolshevism (Princeton, 1978), pp. 175-76. Stites conflates the two bills.

(56.) Huskey, Russian Lawyers, pp. 31-32.

(57.) After 1901 in Prussia, graduates of other secondary schools could study law if they obtained "the linguistic and technical knowledge necessary for a clear understanding of Roman law," but the overwhelming majority of law students continued to come from the classical schools: see James C. Albisetti, Secondary School Reform in Imperial Germany (Princeton, 1983), pp. 286, 289.

(58.) Hannes Siegrist, "Public Office or Free Profession? German Attorneys in the Nineteenth and Early Twentieth Centuries," in German Professions, ed. Cocks and Jarausch, pp. 46-65, quotation on p. 63. See also Kenneth Ledford, From General Estate to Special Interest: German Lawyers, 1878-1933 (Cambridge, 1996); and Ledford, "Conflict within the Legal Profession."

(59.) Drucker, "Vorgeschichte," p. 280.

(60.) Albisetti, Schooling German Girls, pp. 160-62; Berneike, Die Frauenfrage ist Rechtsfrage, pp. 44-96, passim.

(61.) Albisetti, Schooling German Girls, pp. 232, 246; Hiltrud H[ddot{a}]ntzschel, "Justitia--eine Frau? Bayerische Positionen einer Geschlechtsdebatte," in Bedrohlich gescheit, ed. H[ddot{a}]ntschel and Bussmann, p. 198; Drucker, "Vorgeschichte," p. 287.

(62.) Albisetti, Schooling German Girls, pp. 247-48; H[ddot{a}]ntzschel, "Justitia," pp. 200-02; Margarethe Freiin von Erffa, "Die Frau als Rechtsanwalt," in Die Kultur der Frau, ed. Ada Schmidt-Beil (Berlin, 1931), p. 207.

(63.) Ledford, From General Estate, pp. 166-68, 280-82; Erffa and Richarz-Simon, "Der weibliche Rechtsanwalt," pp. 475-77; Vera Lowitsch, Die Frauals Richter (Freiburg, 1933). See more generally Stephan Bajohr and Kathrin R[ddot{o}]idiger-Bajohr, "Die Diskriminierung der Juristin in Deutschland bis 1945," Kritische Justiz 13 (1980): 39-50; and Deutscher Juristinnenbund, ed., Juristinnen in Deutschland: Eine Dokumentation, 1900-1984 (Munich, 1984).

(64.) H[ddot{a}]ntzschel, "Justitia," p. 213. The best study of professional women in the Nazi era is Claudia Huerkamp, Bildungsb[ddot{u}]rgerinnen: Frauen im Studium und in akademischen Berufen, 1900-1945 (G[ddot{o}]ttingen, 1996), on lawyers esp. pp. 287-96.

(65.) For a brief survey of educational opportunities for Austrian women, see James C. Albisetti, "Female Education in German-Speaking Austria, Germany, and Switzerland, 1866-1914," in Austrian Women in the Nineteenth and Twentieth Centuries, ed. David Good, Margarete Grandner, and Mary Jo Maynes (Providence and Oxford, 1996), pp. 39-5 7.

(66.) Martha Forkl and Elisabeth Koffmahn, eds., Frauenstudium und akademische Frauenarbeit in [ddot{O}]sterreich (Vienna, 1968), esp. pp. 17-29; Tichy, "Zur Geschichte des rechtswis-senschaftlichen Studiums," pp. 277-79; Edmund Bernatzik, Die Zulassung der Frauen zu den juristischen Studien (Vienna, 1900). For a less favorable response, see Maria Steibl, "Frauenstudium in Osrerreich bis 1945, dargestellt am Beispiel der Innsbr[ddot{u}]cker Studentinnen," (inaug. diss., University of Innsbruck, 1987), pp. 60-66.

(67.) See, for example, Anna Lind, "Das Frauenstudium in [ddot{O}]sterreich, Deutschland und der Schweiz," (law diss., University of Vienna, 1961), pp. 87-88. I know of no archival research explaining the government's decision.

(68.) Jahresbericht des Vereins f[ddot{u}]r erweiterte Frauenbildung Wiens 21 (1908-09): 24-25; Tichy, "Geschichte des rechtswissenschaflichen Studiums," pp. 279-82.

(69.) Addeo, Evatogata, p. 150; Austria, Bundesministerium f[ddot{u}]r Justiz, Beitr[ddot{a}]ge zum Thema: Die Juristin in die Justiz (Vienna, 1969), pp. 75-76; Ulrike D[ddot{o}]cker, "Das gelebte Pathos: B[ddot{u}]rgerliche M[ddot{a}]nnlichkeitsideale und M[ddot{a}]nnerpraktiken in der (Berufs-) Welt von Advokaten," in Margret Friedrich and Peter Urbanitsch, eds., Von B[ddot{u}]rger und ihre Frauen (Vienna, Cologne, and Weimar, 1996), pp. 116--17.

(70.) These are treated more briefly because of the limited source material available in languages the author reads.

(71.) Siegrist, Advokat, p.444; Frank, La femme-avocat (II), pp. 100--104; Charrier, L'[acute{e}]volution, pp. 477--78; Addeo, Eva togata, pp. 148--49; Ingrid Bohn, "Einsamkeit und Freiheit: Die Anf[ddot{a}]nge akademischer Bildung f[ddot{u}]r Frauen, das Beispiel Schwedens," Zeitschrift f[ddot{u}]r Geschichtswissenschaft 47 (1999):20--21.

(72.) Frank, La femme-avocat (II), pp. 105--06; Addeo, Eva togata, p. 147.

(73.) Frank, La femme-avocat (II), p. 106; Charrier, L'[acute{e}]volution, p. 467.

(74.) Ostrogorskii, Rights of Women, p. 153; Frank, La femme-avocat (II), p. 98; Inga Dahlsgard, Women In Denmark: Yesterday and Today, trans. Geoffrey French (Copenhagen, 1980), p. 112.

(75.) Charrier, L'[acute{e}]volution, p. 441; Algardi, La donna e la toga, p. 33.

(76.) Cahiers f[acute{e}]ministes, 15 March 1899, p. 2; ibid., 1 May 1903, p. 2; Addeo, Eva togata, p. 148. Elisabeth van Dorp had numerous publications, including a book in English: A Simple Theory of Capital, Wages, and Profit or Loss (London, 1937). See also the reminiscences of another Dutch attorney, Estella Simons, "Kurzes Lebensbild," in F[ddot{u}]hrende Frauen Europas, ed. Elga Kern (Munich, 1930), pp. 104--07.

(77.) Charrier, L'[acute{e}]volution, pp. 472, 442; Erffa and Richarz-Simon, "Der weibliche Rechtsanwalt," p. 480.

(78.) Addeo, Eva togata, pp. 148--51; Charrier, L'[acute{e}]volution, p. 473.

(79.) Algardi, La donna e la toga, pp. 34--35; Virginia Paskaleva, "L'[acute{e}]mancipation professionelle et socio-politique de la bulgare du debut du XXe si[grave{e}]cle [grave{a}] la deuxi[grave{e}]me guerre mondiale," Etudes historiques 14 (1990): 141, 145; Kov[acute{a}]cs, Politics of the Legal Profession, p. 1.

(80.) Chauvin, [acute{E}]tude historique, esp. pp. 239--47; Santoni-di Sio, La donna; Frank, La femme-avocat (I) and (II); Ostrogorskii, Rights of Women, pp. 143--53. On Frank, see Francoise de Bueger-van Lierde, "Louis Frank, pionnier du mouvement f[acute{e}]ministe belge," Revue belge d'histoire contemporaine 4 (1973): 377--92.

(81.) Kempin's arguments to the court are reprinted in Stadler-Labhart, "Erste Studentinnen," pp. 107--12; and in Delfosse, Emilie Kempin-Spyri, appendix.

(82.) Drachman, Sisters in Law, appendix 1. It is not clear if Adolphine Kok had to argue her case in the Netherlands, or was simply allowed to register.

(83.) Delfosse, Emilie Kempin-Spyri, p.43; Frank, La femme-avocat (II), p. 7l; Lang, British Women, pp. 146, 148; Jean Signorel, La femme-avocat (Toulouse, 1894), p. 46.

(84.) Santoni-di Sio, La donna, p. 172; Chauvin, [acute{E}]tude historique, p. 9; Viviani in France, Chamber of Deputies, D[acute{e}]bats parlementaires, 7th legislature, 30 June 1899, p. 1,764; Vandervelde cited in Cahiers f[acute{e}]ministes, 6, no. 1(1 March 1901); Henri LaFontaine, La femme et le barreau (Brussels, 1901), pp. 7--8; Helena Migerka, "Die Zulassung der Frauen zum Rechtsstudium," Frauenleben 12, no. 5 (May 1900): 2.

(85.) Santoni-di Sio, La donna, pp. 39, 43, 65, 137, 53; Frank, La femme-avocat (II), pp. 81, 83; August Forel, R[ddot{u}]ckblick auf mein Leben (Zurich, 1935), p. 190; Taricone, Teresa Labriola, p. 14.

(86.) Santoni-di Sio, La donna, pp. 3, 68, 87; Frank, La femme-avocat (II), p. 287; Holford Knight, "Women and the Legal Profession," Contemporary Review 103 (May 1913): 689.

(87.) Santoni-di Sio did indicate that he was going to write a second volume on the "social," as opposed to the "legal," aspects of female attorneys; but he never did so. From his summary of its intended contents, however, it does not appear that he planned to raise such issues: La donna, pp. ix-x.

(88.) Madame Potonie-Pierre in Congr[acute{e}]s francais et international du Droir des Femmes (Paris, 1889), p.218.

(89.) Delfosse, Emilie Kempin-Spyri, p. 62; Frank, La femme-avocat (11), pp. xv, 140, 162.

(90.) Popelin in Women in Professions, Being the Professional Section of the International Congress of Women, London, July 1899 (London, 1900), pp. 13-14; "Madame Chauvin et Monsieur Magnaud," Cahiers f[acute{e}]ministes 6, no. 1(1 March 1901); LaFontaine, La femme, p. 12; Lang, British Women, p. 150.

(91.) Joyce Antler has pointed out that arguments about special needs and/or talents also played a secondary role in campaigns to open the American bar: The Educated Woman and Professionalization: The Struggle for a New Feminine Identity, 1880-1920 (New York, 1987), p. 267.

(92.) Howsam, "'Sound-Minded Women,'" p. 52.

(93.) Santoni-di Sio, La donna, pp. 11-12; Frank, La femme-avocat (II), p.71.

(94.) Lucien Leduc, La femme devant la parlement: [acute{E}]tude du f[acute{e}]minisme et des projets de loi relatifs [acute{a}] l'extension des droits de lafemme (Paris, 1898), p. 304.

(95.) Frank, La femme-avocat (II), p. 81; Gourju cited in Charrier, L' [acute{e}]volution, p. 344; "Of the Admission of Women to the Legal Profession: A Word in Favor, by a Solicitor," Englishwoman 9 (Jan.-Mar. 1911): 299.

(96.) Gabba cited in Franca Pieroni-Bortolotti, Alle origini del movimento femminile in italia, 1848-1892 (Turin, 1963), p. 122; Gierke in Kirchhoff, Die akademische Frau, p.26; "Women and the Bar," The Spectator 91(1903): 1,017.

(97.) Francis Xavier Godts, Erreurs et crimes enfait d'[acute{e}]ducation: le f[acute{e}]minisme condamn[acute{e}] par les principes de th[acute{e}]ologie et de philosophie (Roulers, 1903), pp. 10, 218, 281.

(98.) Marcus Reed, "Is Portia Possible?" MacMillan's Magazine, n. s., 1(1906): 382, 377; Charles Turgeon, Le f[acute{e}]minisme francais (2 vols.; Paris, 1902), p. 460.

(99.) Kempin in Drachman, Women Lawyers, p. 105; Lacombl[acute{e}] cited in Frank, Lafemme-avocat (II), p. 81; Algardi, La donna e la toga, p. 17; Lang, British Women, p. 149; Arthur Baumann, "The Future of the Bar," The Nineteenth Century and After 81 (March 1917): 630.

(100.) Julius Caduff, Ober Emancipation der Frauen: Bin Vortrag (Chur, 1868), p. 10; Destr[acute{e}]e cited in Frank, La femme-avocat (II), p. 8l; Turgeon, Le f[acute{e}]minisme francais, 1: 464; Lang, British Women, p. 155; Franz, English Women, p. 275.

(101.) Laband in Kirchhoff, Die akademische Frau, p. 29; Lowitsch, Die Frau als Richter, pp. 66-70; Josef T. Goldberger, "Vom Berufe der Frauen unserer Zeit f[ddot{u}] die Rechtspfiege," Die Frau 26 (1918-19): 276.

(102.) Siegrist is highly skeptical of much of the rhetoric about overcrowding, even in Germany; see Advokat, p. 432.

(103.) Agostino Bertani, Scrirri e discorsi, ed. Jessie White Mario (Florence, 1890), p. 301; Leduc, La femme devant le parlement, p. 19; LaFontaine, La femme et le barreau, p. 17; E. Z[ddot{u}]rcher, " Die [ddot{o}]ffentliche rechtliche Stellung der Frau," in Die Frauenbewegung in der Schweiz, ed. Pestalozzigesellschaft (Zurich, 1902), pp. 38-39; Holford Knight, "Women and the Legal Profession," Contemporary Review 103 (1913): 692.

(104.) Reed, "Is Portia Possible?" p. 382; Marghieri cited in Santoni-di Sio, La donna, p. 40; De Bueger-van Lierde, "A I'origine," p.1,132; Lang, British Women, p. 163.

(105.) I am not sure where this cartoon appeared first. It is reproduced, with a German caption, in Eda Sagarra, An Introduction to Nineteenth-Century Germany (Harlow, 1980), p. 249.

(106.) Bar in Kirchhoff, Die akademische Frau, p. 19; protocol of Prussian Ministry of State for 13 April 1905 in Geheimes Preussisches Staarsarchiv, Abteilung Merseburg, Rep. 90a, Abt. B, Ill 2b, No. 6, Vol. 150; Erna von Langsdorff, "Die Berufsaussichten derJuristin in Deutschland," Die Frau 20 (1892-93): 608; Ludwig Wahrmund, Akademische Plaudercien zur Frauenf rage (Innsbruck, 1901), p. 106.

(107.) Taricone, Teresa Labriola, p. 16; France, Chamber of Deputies, D[acute{e}]bats parlementaires, 7th legislature, 30 June 1899, P. 1,764; Delfosse, Emilie Kempin-Spyri , p.38. See the similar views expressed by judges in Illinois in 1869 and Wisconsin in 1875, cited in D. Kelly Weisberg, "Barred from the Bar: Women and Legal Education in the United States, 1870-1890," Journal of Legal Education 28 (1977): 488.

(108.) Information in this paragraph comes from Richard J. Evans, The Feminists: Women's Emancipation Movements in Europe, America, and Australasia, 1840-1920 (London and New York, 1977), pp. 218-24; and Lynne Brakeman and Susan Gall, eds., Chronology of Women Worldwide (Detroit, 1997). Note that Belgium in 1919 granted the vote only to widows and mothers of war victims, Portugal in 1931 to women with a secondary education.

(109.) Hause, Women's Suffrage, pp. 71-73.

(110.) See note 8 above.

(111.) Geraldine Joncich Clifford, ed., Lone Voyagers: Academic Women in Coeducational Universities, 1870-1937 (New York, 1989).

(112.) There is no mention of Orme in Lang, British Women, or in Ray Strachey, The Cause: A Short History of the Women's Movement in Great Britain (London, 1928). Strachey does mention Cornelia Sorabji, but not Bertha Cave, Gwyneth Bebb, or Ivy Williams.

(113.) Dudgeon, "Women and Higher Education," p. 161.

(114.) See references in note 20.

(115.) France, Chamber of Deputies, D[acute{e}]bats parlementaires, 7th legislature, 30 June 1899, p. 1,758.

(116.) Hause, Women's Suffrage, pp. 84-85.

(117.) Backhouse, Petticoats and Prejudice, p. 337; Drachman, Sisters in Law, appendix 1. One could also note that in the 'progressive" United States, women could not attend law school at Harvard University until 1950, at the University of Notre Dame until 1966.

(118.) Alan A. Patterson, "The Legal Profession in Scotland: An Endangered Species or a Problem Case for Market Theory?" in Lawyers in Society, ed. Abel and Lewis, 1: 93.

(119.) Streiter, "Die Rechts- und Staatswissenschaftliche Fakult[ddot{a}]t," p. 181.
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