§  166.]         BESTBIOnONS  ON  THE  BIGHT  TO  PBBFEB.  221

ware,^  Iowa,*  Kansas,'  New  Hampshire,*  Michigan,*  and
Missouri,*  general  assignments  giving  preferences  are  de-
clared fraudulent  and  void.  In  Massachusetts,^  assign-
ments, whether  with  or  without  preferences,  are  equally
voidable  by  creditors  not  parties  to  them.  In  Maine,*
every  assignment  made  for  the  benefit  of  creditors  is  re-
quired to  provide  for  a  proportional  distribution  of  all  the
real  and  personal  estate  of  the  debtor,  except  what  is  ex-
empt from  attachment,  among  all  the  creditors  becoming
parties  thereto ;  and  in  whatever  form  made,  or  however  ex-
pressed, is  declared  to  have  the  same  effect.  In  Vermont,^
all  assignments  are  required  to  be  for  the  benefit  of  all  the
creditors  of  the  assignor,  in  proportion  to  their  respective
claims,  anything  in  such  assignments  to  the  contrary  not-
with^nding.  In  lUinois,^^  preferences  are  void,  and  all
debts  within  the  provisions  of  the  assignment  are  to  be  paid
jpTO  rata.  In  Minnesota,^^  stringent  provisions  are  made
against  preferences,  and  a  confession  of  judgment,  with  in-


'  Revised  Code  of  Delaware  (ed.  1874),  c.  182,  §  6.
*  Code  of  Iowa  (ed.  1880),  title  U,  c.  7,  §  2116.    See  end  $  162.
*  General  Statutes  (ed.  1868),  c.  6,  §  1,  p.  98;  Comp.  Laws  (1879),  p.  99.
*  General  Laws  (ed.  1878),  c.  140,  §  1,  p.  885;  True  ▼.  Oongdon,  44  N.  H.  48.
'  Laws  of  1879,  c.  198;  Laws  of  1881,  c.  278;  see  Pierson  y.  Manning,  2
Mich.  445.
*  General  Statutes  of  Missouri  (ed.  1879),  vol.  I,  c.  5,  p.  54.
*  See^KW^  p.  229.
'  Reyised  Statutes  of  Maine  (ed.  1871),  p.  548.  Th&  former  act  of  April  1,
1836  (3  Laws  of  Me.  560,  c.  761),  prohibitea  preferences.  Pike  y.  Bacon,  21  Me.
