106 Notes and News. [^ a ll n k 



crippled him so completely that during the remainder of his life he was 

 confined to a wheel chair and able to accomplish but very little field work, 

 although he used his pen pretty steadily until the last. Ornithologists 

 are indebted to him for many valuable field notes and critical observations, 

 as well as for his lists of Michigan birds. He also published one or more 

 lists of Michigan reptiles, and did some work on the mammals of the 

 State during his later years. His collections of birds and mammals were 

 purchased many years ago by the Michigan Agricultural College and the 

 University of Michigan. — W. B. B. 



The Fourth Annual Meeting of the National Association of Audubon 

 Societies was held at the American Museum of Natural History, New 

 York City, October 27, 1908. To facilitate the work of the Association 

 several changes were made in the By-Laws, reducing the number of Direc- 

 tors from thirty to eleven, and making six instead of five a quorum. In 

 addition to the Board of Directors, an Advisory Board was established, 

 "consisting of not less than ten nor more than thirty members," to which 

 the Board of Directors may submit any matter for advice. With a large 

 and widely scattered Board of Directors it has been found impossible to 

 secure a satisfactory attendance at meetings; a smaller Board, with a 

 more concentrated residence, seemed to promise greater efficiency in the 

 transaction of business. The following officers were elected for the ensuing 

 year: President, William Dutcher; First Vice-President, Dr. T. S. Palmer; 

 Second Vice-President, Dr. J. A. Allen; Secretary, T. Gilbert Pearson; 

 Treasurer, Dr. Jonathan Dwight, Jr. Upon invitation of Mr. Gifford 

 Pinchot, the following Committee was appointed, to cooperate with the 

 National Conservation Commission: Edward Howe Forbush (Chairman), 

 Dr. T. S. Palmer, Frank M. Chapman, T. Gilbert Pearson, William Dutcher. 

 Following the reports of the President, Secretary and Treasurer, an illus- 

 trated address was given by Mr. William L. Finley on the work of the 

 plume hunter in Oregon. The work of the Association for the year 1908, 

 as detailed in the report of the President, has already been noticed (antea, 

 p. 100). 



An important decision has recently been made by the Supreme Court 

 of the United States respecting the sale in this country of imported game. 

 The decision is that of the Silz Case, which was begun in the courts of 

 Kings County (Brooklyn), New York, in April, 1905. The history of this 

 case is given in full by Dr. T. S. Palmer in ' Circular No. 67 ' of the Bureau 

 of Biological Survey, issued December 9, 1908, on which the following 

 details are based. "On April 6. 1905, John Hill, proprietor of the Claren- 

 don Hotel in Brooklyn, was arrested for having in possession in close 

 season 24 brace of English Plover and Russian Grouse. These birds had 

 been purchased from August Silz, one of the largest importers of foreign 

 game in New York City, Silz at once became a party to the case and on 

 the next day was arrested by Henry Hesterberg, the sheriff of the county, 



