68 PROBLEMS IN WILD LIFE CONSERVATION 



However, another Louisiana statute of 1926 requiring 

 that the head and hull of all shrimp caught in the state be 

 removed before being shipped out was held invalid as im- 

 posing such a burden. 52 Geer v. Connecticut 53 was distin- 

 guished on the grounds that the purpose of the Connecticut 

 statute was to keep wild game exclusively for the use of its 

 citizens by forbidding shipment out of the state, while the 

 Louisiana statute did not require any part of the shrimp to 

 be kept in the state. After the head and hull had been sep- 

 arated, either part could be shipped at will in interstate com- 

 merce in unlimited quantities. Clearly the purpose of the 

 act, said the court, was to require the canning industry to 

 locate its plants in the state and, therefore, it was invalid as 

 imposing a burden upon interstate commerce. If a general 

 rule could be drawn from these decisions, it would seem to 

 be that a state may not interfere with interstate commerce 

 unless for the purpose of keeping the wild animals within 

 the state for the benefit of the people of the state. 



Limitations Imposed by Privileges and Immunities Clause 

 upon State Control: The clause of the United States con- 

 stitution providing that, 54 " The citizens of each State shall 

 be entitled to all privileges and immunities of citizens in the 

 several States," has not proved to be a major check on the 

 state's power of control because of the doctrine that prop- 

 erty in wild animals by right is limited, in each case, to the 

 citizens of the state in which they are found. The United 

 States Supreme Court likened this ownership to that of 

 public domain, saying : 55 



52 Foster-Fountain Packing Co. v. Hay del, 278 U. S. i (1928). 



53 161 U. S. 519, 16 S. Ct. 600 (1896). 



54 Art. iv, sec. i. 



55 McCready v. Virginia, 94 U. S. 395 (1876). 



