
    JAMES F. GLOVER v. THE UNITED STATES.
    [29 C. Cls. R., 236; 164 U. S., 294.]
    
      On the claimant’s Appeal.
    
    This is one of three suits to recover, under the act 2d March, 1891, for the loss of the same property m Beaufort hy tax sales. The question is whether the mortgagor, the mortgagee, or the assignee of the mortgage was the “legal oioner’’ at the time of sale within the meaning of the statute.
    The court below decides:
    1. The mortgagee of lands in Beaufort, S. C., sold under the direct-tax acts, was not the “legal oiune>-” within the intent of the Aot $d March, 1891 (26 Stat. L., 822, § 4).
    *2. The law of South Carolina governs in determining who was the owner of land sold for taxes in that State under the direct-tax acts.
    3. In South Carolina, as is held hy the Supreme Court of that State, a mortgagee is not the owner of land, and a mortgage is not a conveyance, hut simply a contract, whereby the mortgagee obtains a lien. The laws relating to morgages in the different States examined and commented on.
    The decision of the court below is affirmed on the same ground.
   Mr. Justice White

delivered the opinion of the Supreme Court, November 30, 1896.  