REGULATIONS REGARDING SHOOTING. 41 



licenses, however, are required in North Dakota, where it is unlawful 

 to kill any birds without a permit. A sharp distinction is drawn 

 between residents and nonresidents of the State, for residents may- 

 obtain a license for 75 cents, whereas nonresidents must pay $25. In 

 Virginia, nonresidents are prohibited from killing wild fowl below the 

 head of tide water except in Accomac and Northampton counties; and 

 in Missouri they are prohibited from killing certain specified game. 

 Nonresident licenses are required in some of the counties of Maryland, 

 and also in Arkansas, Delaware, Florida, Illinois, South Carolina, South 

 Dakota, West Virginia, and Wisconsin, as well as in British Columbia, 

 Manitoba, Nova Scotia, Ontario, Quebec, and the Northwest Territories. 

 In some States they apply only to game birds; in others they cover all 

 species. The fee ordinarily varies from $10 to $25, but amounts to $50 

 in British Columbia. Full information on this point, as well as on the 

 manner of obtaining permits, may be found in the various State laws 

 or in ' Game Laws in Brief ' (New York, 1900). 



Restrictions regarding bags, or the number of birds which may be 

 killed within a specified time, are becoming rather common; and a few 

 States forbid absolutely the killing of certain birds for sale. Non- 

 export clauses, prohibiting the shipment into other States of birds 

 and game protected by local acts, have been incorporated into the game 

 laws of a number of States during recent years, and have been upheld 

 by the Supreme Court of the United States. 1 Thus, Delaware imposes 

 a fine of $5 for each robin, partridge, quail, or woodcock exported; 

 Massachusetts, a fine of $10, and Rhode Island, a fine of $20 for each 

 ruffed grouse, quail, or woodcock shipped out of the State. Kansas, 

 Michigan, Minnesota, Nebraska, New Jersey, Pennsylvania, and Utah 

 also forbid export of game and certain birds. 



Regulations as to the manner or time of hunting — as, for example, 

 prohibiting the use of swivel guns or shooting between sunset and 

 sunrise — are confined almost entirely to game birds; but laws governing 

 shooting on Sunday apply equally to birds of all kinds. Nine States, 

 the District of Columbia, and several Canadian Provinces, viz, Alabama, 

 Delaware, Maine, Massachusetts, New Jersey, New York, North Caro- 

 lina, Ohio, Pennsylvania, District of Columbia, New Brunswick, 

 Ontario, and Newfoundland, prohibit shooting on Sunday, thus making 

 that day in effect a special close season. 2 



J Geer v. State of Connecticut, 161 U. S-, 519. 



References to Sunday laws are as follows: Alabama, Gen. Laws, 1898-99, p, 77, 

 sec. 1; Delaware, Rev. Stat., 1893, Ch. LV, sec. 7, p. 457; District of Columbia, 30 

 Stat. L., p. 1012; Maine, Laws of 1899, ch. 42, sec. 22, p. 42; Massachusetts, Acts of 

 1899, ch. 116, p. 57; New Jersey, Laws of 1895, Ch. CCLV, sec. 15, p. 478; New York, 

 Penal Code, sec. 1109; North Carolina, Code of 1883, sec. 2837, p. 236; Ohio, Rev. 

 Stat., 1897, sec. 6961,-p. 3198; Pennsylvania, Laws of 1897, No. 103, sec. 1, p. 123; New 

 Brunswick, Laws of 1899, Ch. VIII, sec. 4; Ontario, Laws of 1896, ch. 193, sec. 24; 

 Newfoundland, Act of 1899, sec. 10. 



