8 



Biological Survey, has sent an agent to Argentina, Uruguay, 

 Paraguay and southern Brazil for the purpose of securing 

 " needed information concerning the conditions relating to such 

 of our migratory birds as winter in those regions. 



Constitutionality of the Migratory Bird Treaty Ad affirmed by 

 the Supreme Court of the United States. 

 On January 12, 1920, a letter was received from Louis Mar- 

 shall, Esq., of the firm of Guggenheimer, Untermeyer & Mar- 

 shall of New York City, in which it was assumed that the 

 writer was in favor of sustaining the constitutionality of the 

 migratory bird treaty act, which under the treaty with Great 

 Britain extends protection to our game and insectivorous migra- 

 tory birds throughout the United States. Mr. Marshall, at 

 the instance of the Association for the Protection of the Adi- 

 rondacks, of which he was a trustee, had prepared a brief on 

 this subject, to be presented before the Supreme Court of the 

 United States on March 1, upholding the constitutionality of 

 the migratory bird treaty act. He enclosed the proofs, in 

 which he had quoted extensively from "Useful Birds and their 

 Protection," and requested further information, particularly 

 in regard to the insect food of wild fowl. The material for 

 which he asked was furnished on January 23. On Patriots' 

 Day, April 19, the SuJ)reme Court of the United States rendered 

 a decision sustaining the constitutionality of the migratory 

 bird treaty act, thereby fully legalizing both Federal and inter- 

 national protection of migratory birds and bringing to an end 

 a fight for such protection which had been waged for more 

 than a decade by bird protectionists. It now remains to pro- 

 vide means for enforcing the Federal migratory bird treaty act, 

 as the present appropriation for its enforcement is inadequate. 



Constitutionality of the Migratory Bird Convention Act affirmed 

 by the Supreme Court of Prince Edward Island. 

 On December 8, 1920, a letter was received from Commis- 

 sioner J. B. Harkin of the Department of the Interior, Canada, 

 enclosing a copy of a judgment given by the Supreme Court of 

 Prince Edward Island, sustaining the constitutionality of the 



