474 University of California Publications in Zoology [Vol. 11 



sportsman, whose dog, unless taught otherwise, will surely follow, 

 has fairly no claim to this title, any more than have a snake 

 or a turtle, to either of which a point will generally be made, 

 and these last, it is hardly necessary to add, are neither birds 

 nor game." In some of the eastern states, where the meadowlark 

 is still unprotected, a parasitic worm often found in the small 

 of the back deters many experienced persons from using the 

 bird for food. The western meadowlark cannot be considered a 

 game bird under the definition of such birds given in Section 

 637a of the Penal Code of the State of California. 



9. By a decision of the United States Supreme Court (Geer 

 V. Conn., 161 U. S. 519), birds are considered a national resource 

 belonging to the people as a whole. The destruction of the 

 western meadowlark by the grain grower causes a loss to the 

 growers of alfalfa and other crops who profit enormously by the 

 destruction of insect pests by the bird. 



10. In certain sections of California, notably southern Cali- 

 fornia, because of the small numbers of meadowlarks or owing 

 to the kind of crops raised, the western meadowlark causes no 

 damage and is considered distinctly beneficial. The extent of 

 damage varies with the locality and the kind of crop raised. 



Suggestions for the Protection op Crops 

 In a study of this kind something should be said as to the 

 methods of protecting crops from the depredations of the western 

 meadowlark, for, although we may in general say that the bird 

 is highly beneficial to agricultural interests, yet local conditions 

 and an overabundance of birds may demand protective measures. 

 Scarecrows have proved inefficient as a means of protecting grain 

 fields from attack by meadowlarks. The birds soon become accus- 

 tomed to any object placed in the field, and so continue their 

 depredations. Frightening the birds by shooting is found to 

 be a better means, but is not always practical. It should be 

 remembered that the protective measures suggested are all prac- 

 tical ones, for it has been shown that the damage is limited to 

 two weeks; also that a certain amount of thinning is allowable, 

 and in some cases of value. The outlav of several extra sacks 



