19:4] Bryant: Economic Status of the Western Mrnfloirlark 475 



of grain can be more than counter-balanced by the efficiency of 

 the meadowlarks later in the year when injurious insects have 

 become abundant in grain fields. 



Where losses to crops warrant protective measures the fol- 

 lowing are proposed : 



1. Plant grain deeply. It assures a better crop regardless of 

 losses due to meadowlarks. Drilled grain gives a better yield 

 than broadcasted and is also l)etter protected from the attack of 

 meadowlarks. 



2. Fields bordering pasture or uncultivated land, if sowed 

 more heavily along such margins, will usually be a.s.sured a 

 normal crop. 



3. Meadowlarks are easily frightened from a field liy the 

 noise of shooting or by a dog. As damage is limited to a short 

 period of time, this method seems practical on small fields. 



Recommendations as to Legislation 



The United States Supreme Court (Geer v. Conn.. 161 U. S. 

 519) has ruled that all game and wild birds belong to the people. 

 The decision of the court in a test case in California is as follows : 

 "We take it to be the correct doctrine in this country that the 

 ownership of wild animals, so far as they are capable of owner- 

 ship, is in the State, not as a proprietor, but in its sovereign 

 capacity as the representative and for the benefit of all its people 

 in common (State v. Rodman, I. c). Consequently the people, 

 through their various legislatures, control this natural resource. 

 It is evident, therefore, that as in other things, the majority rule. 

 In legislation the rights of the many are often clouded over by 

 the activities of the few. Sometimes this is due to inactivity 

 on the part of the many ; sometimes it is due to a lack of knowl- 

 edge on the part of the many and an accurate knowledge by the 

 few. In the ease before us we desire that there shall be no lack 

 of information on either side. 



The desire on the part of certain rauehei's of the state to 

 place the western meadowlark on the unprotected list in the 

 hope that it might be so reduced in numbers as to prevent injury 

 to crops, and the desire of certain sportsmen to add this bird 



