“Be it further enacted by the Authority aforesaid, That the several Towns in the Province shall have Power, and they are hereby directed…to chose and appoint two meet Persons whose Care and Duty it shall be to inform of all Breaches of this Act, and to take Care that the Violaters thereof be duly prosecuted and punished…” (Massachusetts General Court, 1739, p. 688).

Content Warning: This multi-part blog post contains references to hunting, agriculture, and research practices of killing birds and other wildlife. If you decide not to read on, I respect and admire your choice.

[This post picks up where the last left off. For recaps and links to the rest of the series, please visit my Mallard page.]

Dibs on the Deer

Game legislation, in the pre-revolutionary colonies, started with deer.

With deer in Massachusetts. In 1739.

As wave after wave of European immigrants divvied up the Atlantic coast of North America, the political and social habits of aristocracy proved difficult to shake. Colonists may have envisioned a democratic continental future, in which the people (the invading people, that is) owned the continent’s resources, but pre-revolutionary lawmakers hoarded up resources according to Europe’s aristocratic precedent.

In Massachusetts, in 1739, that meant hoarding up the deer.

The wordily convoluted law quoted as an opening epigraph, above, was filed as “An act in addition to an act entitled, An act for the better preservation and increase of deer within this Province”.¹ The new-and-improved 1739 edition aimed to halt the decline of deer populations by reinforcing seasonal hunting restrictions: “Whereas the penalties already provided in and by an act pass’d in the tenth year of the reign of King William the Third…have proved ineffectual to answer the good ends in said Act proposed…” (Massachusetts General Court, 1739, p. 687).

Starting on December 10th of 1739, deer were off the hunting menu. Deer season would reopen on August 1st, 1740, and the schedule would repeat indefinitely. From August 2nd to December 9th, annually, the citizens of Massachusetts could enjoy late autumn/early winter’s open season on deer. But during the rest of the year, deer meat and deer hides were forbidden harvests. Anyone caught with fresh meat or hides (or said to be in possession of such, by any two informants) would be prosecuted.

To enforce this seasonal hunting ban, the revised act required each town to appoint two official informants to monitor and prosecute (persecute?) deer hunters, with expansion of the informant network written into the statute: “…appoint one or two meet persons in every such new plantation wherein ten or more families are settled, to inform against and prosecute the Violaters of this Act” (p. 688).

Should any of the appointed informants decline the position, and/or decline to swear the informant’s oath, anyone could sue them for the sum of £5 (p. 688). (According to an online conversion calculator, that’s a fine roughly equivalent to $1500, in 2026 US dollars.) As the statute does not specify a one-time fine, I envision a line of friends and coworkers demanding payment from some poor soul who slept through the meeting, didn’t know they had been nominated and elected, and couldn’t bring themselves to sign on as an informant.

Oaths aside, informants generated their own wages. Anyone convicted² of killing the king’s province’s deer owed £10 per deer, divided between the informant and “His Majesty for the Support of this Government” (p. 687). When a convicted hunter couldn’t pay the fine, they faced jail for 30 days or forced labor for two months.

All of this means that Massachusetts’s 1739 deer informants had the statutory power to persecute (prosecute) deer hunters. To drive the colony’s deer hunters first into poverty and then into slavery.

Aside: The Robin Hood Perspective

I grew up on a steady diet of Robin Hood.³ As a fan of the trope, all of this 1739 fuss about the king’s deer resonates.

I have lingering nostalgia for Robin McKinley’s reluctant hero in The Outlaws of Sherwood:

There had been outlaws around Nottingham and in Sherwood before, but this sounded like something new—outlaws who believed in king and country, and good English law; who merely rebelled against the heavy hand of tyranny (1988, Chapter Four, para. 15).

And for Peter Beagle’s gruff anti-Marian in The Last Unicorn:

Close by a familiar voice said, ‘Leaving us so early, magician? The men will be sorry they missed you.’ He turned and saw Molly Grue leaning against a tree. Dress and dirty hair tattered alike, bare feet bleeding and beslimed, she gave him a bat’s grin. ‘Surprise,’ she said. ‘It’s Maid Marian.’ (1968, p. 82)

Awash in Robin Hood, I’m pre-disposed to favor pure-hearted bandits living in the woods. To expect corruption among government officials charged with imprisoning and enslaving the pure-hearted bandits. Reverse tropes, in which bandits are greedy and officials pure-hearted, simply don’t resonate. I can’t recall any among my best-loved childhood books.

Robin Hood taught me skepticism for a system in which police generate their own salaries through imposing fines and confiscating property. Especially when the system polices those who have less power, less security, and less food.⁴

My skepticism will be apparent throughout this installment. It’s likely apparent in everything I write and everything I do.

This is the strength of fairy tales and myths and legends. Here in my middle years, all these many Robin Hoods float on the surface of my memories, jostling and reinforcing each other. Resonating.

As with my previous installment, caveat lector.

Policing the Hunt in the 1800s

Skipping ahead to the post-revolutionary colonies, game legislations gained popularity and momentum throughout the 1800s.⁵ As game legislation ballooned into a regulatory industry, bureaucratic vacuum energy organized into committees, commissions, and agencies. Various departments staked claims in wildlife as a regulated resource: game and fisheries departments, of course, but also agriculture, public lands, education, and commerce.

Wrangling with ways to police and enforce game laws, legislatures were forced to wrangle, also, with funding. So many interests. So much legislation.

“In many States it has been found well-nigh impossible to secure legislation providing for the appropriation of money, no matter how little, for the preservation of game. The sentiment to which this condition is due still prevails in a large part of this country, particularly in the South. The creation of new offices, with salaries attached, is regarded with great jealousy and disfavor”⁶ (Williams, 1907, p. 34).

Non-random examples: Incentivizing informants on both coasts

In funding game police, early statutes in California and Virginia resorted to borrowing (unknowingly?) from Massachusetts’s 1739 system. They legislated kickbacks for informants.⁷

In 1841, Virginia paid informants a half-share of fines collected from non-residents caught hunting waterfowl below the head of the tidewater (General Assembly of Virginia, 1841, pp. 88–89). As each fine was $100, informers could expect a payout of $50 per prosecution—a purchasing power of somewhere around $2000 in today’s (2026) economy.

About a decade later, in 1852, California informants were eligible for half-shares of fines. California fines were lower ($50) but were not limited to prosecuting non-residents (California Legislature, 1852, p. 134). The 1852 statute protected quail, mallards, and wood ducks and shut down the game markets for these birds during closed seasons. This statute put market hunters and market peddlers under extra surveillance. Informants didn’t need to slog out into the wild, to catch hunters in the act of shooting or collecting birds. They could simply stay in town and wait for sellers to open shop.

Who could resist the lure of an informant payday equivalent to $1000 or $2000, in today’s money?

My faith in humanity feels that almost everyone would resist such a lure, if their starving neighbors resorted to shooting mallards. My skepticism argues otherwise.

Aside: About those debtors’ prisons

“The only punishment authorized under many of the older game statutes was a fine, and if the defendant was impecunious he escaped punishment altogether. A very considerable portion of offenders against the game laws are of this class, and experience has demonstrated that to secure obedience the alternative corrective, imprisonment, must be allowed; otherwise many violations go unpunished” (Williams, 1907, p. 74).

That quotation comes from a 1907 bulletin written by a member of the US Department of Agriculture’s Biologic Survey. My current self sees the cruelty in this logic—the cruelty and wickedness of debtors’ prisons. But as a young adult, despite all my Robin Hood reading and my own family’s orbital decay, I lacked such perspective. Young-adult-me would have nodded her agreement on the question of punishment.

On matters of the carrot vs. the stick, I had been raised by the stick and believed in the effectiveness of sticks. I had no personal experience with carrots.

Which cycles back, again, to resonances. In all of this reading through legislative and legal literatures from the late 1800s and early 1900s, I keep finding echoes of my own youthful voice. Perhaps such resonance is part of my perseveration.

Perhaps I keep reading because the resonance keeps ringing, calling me deeper and further into this particular branch of the Mallard Mine.

Perhaps I’m hoping that the metaphor will hold up. That the legislative and legal literatures of the US will grow to understand, as I have, the wisdom of carrots and the anxious futility of sticks. Perhaps I’m hoping that US policy will mature into a reality in which feeding hungry Mallard hunters is more productive than jailing them. In which feeding hungry families is preferable, on every level, to fining them, confiscating their belongings, and selling off their property for the enrichment of government-appointed police.

Which brings me to Maryland’s Board of Special Police, legislated into existence in 1880 for the express purpose of protecting waterfowl.

The Ducking Police

“The said Board of Special Police and its deputies shall have power to arrest, with or without warrant, upon their own view, or upon credible information, all persons violating any provisions of said original act, or any of its supplements, and to carry such person or persons before any justice of the peace…”. (Maryland General Assembly, 1880, p. 159)

The said Board of Special Police, later dubbed the Ducking Police, protected waterfowl on the Susquehanna Flats and on the waters of the Chesapeake Bay north of the Turkey Point lighthouse. (North, also, of a vaguely defined point 1/2 mile north of Spesutia Island.)

Maryland placed a notable statutory check on members of the Ducking Police—each appointee was required to register a bond with the clerk of their respective Circuit Court. The Ducking Police swore to be faithful to their duties, under threat of a $1000 penalty. (This penalty would run somewhere in the range of $30,000 worth of purchasing power, in today’s economy.) The statute required appointees to provide proof, to the clerks of their Court, that they could pay such a penalty (Maryland General Assembly, 1880, p. 160). Written as a rein on corruption, the most immediate effect of this requirement was to limit the recruitment pool to hunters wealthy enough, already, to post such a bond.

In payment for their faithful service, members of the Ducking Police shared an end-of-the-year jackpot made up of license fees collected from residents registering to hunt in Cecil and Harford counties, including boat licensing fees, and of fines collected from prosecutions.

In 1880, the fledgling Ducking Police had a single assignment: arrest anyone caught with ducks in their possession during the close season (April 1–October 31). Being caught with a duck during close season was “prima facie” evidence of a violation (Maryland General Assembly, 1880, p. 160). Courts were given wide discretion regarding fines, which could range anywhere between $5 and $100, and the collected fines went straight into the Ducking Police jackpot.

What are the chances that this system was immune to corruption?

The jackpot grew sweeter over time. By 1888, fines of $50–100 could be imposed for hunting at night, hunting during close season (April 1–October 31), shooting from a boat within 1/4 mile of shore, using a “big gun” (one that couldn’t be fired from the shoulder), or hunting from an unlicensed sneak boat or sink box (these $50–100 fines for unlicensed watercraft functioned as instant kickbacks, and collected fines were immediately distributed: 1/2 to the arresting officer and 1/2 to the attesting informers) (Maryland General Assembly, 1888, pp. 1382–1384).

Even bigger bonuses came with catching harvest thieves, who were subject to confiscation of their hunting equipment. Pick up some other hunter’s bird, lose your boat and guns and ammo to the Ducking Police. All proceeds from the sale of confiscated equipment went to the arresting officer. (Maryland General Assembly, 1888, pp. 1382–1384)

By 1916, fines had grown to $100–500, and new revenue streams came from regulations around engine exhausts and noise. Confiscations increased, as well, with property seizure rolled into almost every arrest. Proceeds from sales of confiscated equipment were divided between the informers and the arresting officers, though 1/2 of the proceeds from a small subset of these sales went into the county school funds. (Maryland General Assembly, 1916, pp. 1525–1536)

Maryland’s 1916 legislations coincided with an era of federal takeover, as far as migratory waterfowl were concerned. While this federal intervention may have had little or no bearing on changes within the Board of Ducking Police, there’s notable timeline overlap. By 1920, the federal takeover was all-but complete, and by 1927 the Ducking Police jackpot had dwindled to a fixed stipend of $400 per hunting season (Maryland General Assembly, 1927, p. 612).

Finally, in 1941, Maryland dissolved the Board of Ducking Police (Maryland General Assembly, 1941, p. 326).

No more game informants

I can’t pinpoint an accurate timeframe for the end of regulatory informant-policing of game. Nonetheless, the practice did end. At least, statutorily.

But the eventual demise of informant-policing (of game) in the US is a mixed-bag sort of win:

“It was never a success in this country, most men preferring to see the laws violated rather than appear as prosecuting witnesses against their fellow-citizens. Aside from sentiment, such a course was often hazardous to the property and even the life of an informer” (Williams, 1907, p. 75).

So informing was both ethically objectionable and potentially hazardous.

I wanted to spend at least one paragraph unpacking my thoughts, here, but each attempt circled and contradicted and wheezed off into a muddy muddle. Which is a fairly accurate depiction of my self-growth process. I circle and contradict and wheeze around in the mud for unpredictable periods of time, searching for clarity. Sometimes I write poems in the mud. (Poetry is a blurry lens, anyway.) Given the depth of the mud, in this particular pond, I’ll be here a while.

Dabbling.

In the meantime, I’ll circle back to the 1880s. Where court cases document the final years of the meat-and-feathers markets.

Driving the markets underground: One toe over the (commerce) line

The subtext of game legislations, in the mid- and late-1800s, was the ongoing power struggle between market hunters and sport hunters. (See the previous post, Part VI, for an overview of the market vs. sport dynamic.) From the start, sport hunters held a decisive advantage—access to legislative power.

Often men of wealth and leisure, sport hunters in and around state legislatures lobbied for game regulations that hindered market hunters. Folding their arguments into early frameworks for wildlife conservation, sport hunters pointed to rapid species declines that were evident across the North American continent.

Rapid declines in game species affected market hunters, too, forcing them farther and farther afield to practice their profession. Farther, in this case, meant across state lines. Which meant interstate commerce. Which proved to be the decisive legislative lever.

These quail aren’t in Kansas anymore: Chicago, 1880

On January 14, 1880, a Chicago merchant named James Magner purchased a box of quail (144 birds) from a seller on South Water Street. Magner ran a game market at 76 Adams Street and had at least two more boxes of quail already in stock, including birds imported from Kansas in December and purchased direct (in Leavenworth, Kansas) on January 10th.

On January 15th, Magner sold at least one unopened box (144 birds) and somewhere between 60 and 100 birds out of his opened-box stock. (I had trouble following the totals, because math, but the totals weren’t the crime. The date was the crime.)

After a court in Cook County convicted Magner of close-season quail possession, he appealed to the circuit court. And, after the circuit court upheld the conviction, Magner appealed to the Illinois State Supreme Court, which is where the record is most visible today: James Magner v. The People of the State of Illinois. Filed at Ottawa February 3, 1881.

Illinois’s updated game statutes (1879) set a January 1–October 1 close season for quail and grouse. Close season for hunting; close season for buying and selling. In other words, in 1879, Illinois shut down quail markets—from January to October, no one could buy or sell quail in Illinois. No one could have quail in their possession.

Magner and other game merchants would have felt the financial sting, set to lose about $200,000 per year if the game market closed altogether (p. 326). (Keeping up my habit of translating these numbers into today’s money, that’s more than $6 million ($6M) in 2026 purchasing power.)

Magner’s state-level appeal, destined for failure, rested on two arguments:

1. “It seems absurd to hold that the inhibition against the purchase and sale of game imported from the State of New York or Kansas is a protection to the game of this State” (Magner v. The People, 1881, p. 326), and
2. the act “…is in violation of that provision of the constitution of the United States which confers upon Congress the power to regulate commerce among the several States” (Magner v. The People, 1881, p. 327).

In ruling for the State, the court countered Magner’s first argument with prevention logic: “…we think it obvious that the prohibition of all possession and sales of such wild fowls or birds during the prohibited seasons would tend to their protection, in excluding the opportunity for the evasion of such law by clandestinely taking them, when secretly killed or captured here, beyond the State and afterwards bringing them into the State for sale, or by other subterfuges and evasions” (Magner v. The People, 1881, p. 331).

The court’s counter for Magner’s interstate commerce argument followed a complex legal thread anchored in England. The thread starts with a reference to Sir William Blackstone’s Commentaries on the Laws of England and winds through precedents in Massachusetts, Indiana, New York, and Vermont, to establish a foundation of State ownership of game (pp. 333–334):

“Stated in other language, to hunt and kill game, is a boon or privilege granted, either expressly or impliedly, by the sovereign authority—not a right inhering in each individual; and, consequently, nothing is taken away from the individual when he is denied the privilege, at stated seasons, of hunting and killing game. It is, perhaps, accurate to say that the ownership of the sovereign authority is in trust for all the people of the State, and hence, by implication, it is the duty of the legislature to enact such laws as will best preserve the subject of the trust and secure its beneficial use, in the future, to the people of the State. But in any view, the question of individual enjoyment is one of public policy, and not of private right” (p. 334).

From there the court’s thready argument knots tight on Welton v. State of Missouri, an 1876 U.S. Supreme Court case about license taxes for vendors in Missouri, which noted, “The fact that Congress has not seen fit to prescribe any specific rules to govern inter-State commerce does not affect the question. Its inaction on this subject, when considered with reference to its legislation with respect to foreign commerce, is equivalent to a declaration that inter-State commerce shall be free and untrammelled” (p. 282). In other words, the federal government might have constitutional authority over interstate commerce, but, since Congress had never acted on that authority, the default status of non-regulated interstate commerce applied.

The thread spools on, turning new knots at case law involving steamboats, fuel mixtures, and suppression of liquor markets. Hitched, at last, to this handful of unstable rulings, the opinion in Magner v. The People states, “There can not be a constitutional right to transport property which can not legally be brought into existence” (p. 336).

Mic drop? No such thing, in legal literature…

The smoldering net (these quail were most likely netted, so there aren’t any smoking guns) was stashed in Kansas law. Magner’s quail weren’t legally harvested, in the first place. As products of illegal hunting, they never fit the definition of “commerce”. They were illegal goods in Kansas, shipped and transported illegally into Illinois.

After citing all that case law, the entire thread of logic was irrelevant. None of the stickier arguments around commerce even applied, because the birds weren’t commerce.

What they actually were, if they weren’t commerce, isn’t specified. This becomes important in later case law, though, for the case at hand, the important point was settled. The quail weren’t commerce, the interstate commerce clause wasn’t relevant, and Magner needed to pay his fines.

Chicago’s game markets had been put on notice. So had all of the other game markets, in all of the other states.

To be continued…

The next post (or two or three) will get deeper into the final era of game markets, complete with game smugglers. Also, federal interventions and the beginnings of the North American model of wildlife conservation.

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Notes

1. In quoting this act, I edited for readability. If you follow the link to the online copy of the text, you’ll find an elaborate collage of fonts and special characters. I tried, initially, a more faithful reproduction, but it made my eyes ache. Here’s an example:

“WHEREAS the Penalties already provided in and by an Act paſs’d in the Tenth Year of the Reign of King WILLIAM the Third, entitled, An Act for the better Preſervation and Increaſe of Deer within this Proviǹce, have proved ineffectual to anſwer the good Ends in ſaid Act propoſed…”.

My eyes, not to mention my OCD brain, doth protest.

Mostly italics, salted with capitals, peppered with the archaic long s (that’s the one that looks like an f: “ſ”), and spiced with an un-reproducible (with my limited tech skills) c–t ligature—it’s just too much.

Even so, I felt a twinge of regret, reducing the recipe to blog blandness. And a tiny urge to write a time-travel story about an 18th century typesetter who finds fame, in 2025, as a font programmer. Because my OCD, which was part of my reason for editing in the first place, is still fuming that I couldn’t find a way to include that dratted c–t ligature in this footnote. (Click here to return to your regularly scheduled paragraph.)

2. Acceptable proof of guilt included being caught with deer, with meat from deer, or with fresh hides. For offenders who off-loaded carcasses and hides before getting caught, testimony from two credible witnesses regarding two separate events within the last two months would suffice. All of these pairings, in this statute, make my OCD itch—two informants per town or settlement, two witnesses testifying to two infractions over a two month period…it’s at least two twos too many. (Click here to return to your regularly scheduled paragraph.)

3. Robin Hood tropes breach the barriers between history and fiction. Between the reference section and the fantasy shelves. That’s part of why I indulge in this kind of aside. When these entities come into conversation with each other, the result is often chaos. But sometimes, every so often, radiant patterns emerge. A signal in the blog noise that makes writing and reading blogs worthwhile. (Click here to return to your regularly scheduled paragraph.)

4. My personal definition of power, of privilege, is the ability to live in predictably benign surroundings. To wake, most mornings, expecting another ordinary day. Another ordinary meal. Another set of ordinary tasks. Living in predictably benign surroundings equates to impact resistance. To rotational inertia. To a daily expectation that the world will spin on, benignly. Even under stress conditions, the world spins on. Benignly. The force required to perturb the system into non-benign behavior is roughly proportional to the power and privilege at hand. (Click here to return to your regularly scheduled paragraph.)

5. My excavations in the various state literatures reveal a tempting timeline pattern. During this period of time, game legislations spread in rates reminiscent of epidemiology. Almost as if certain pieces of legislation, such as outlawing punt guns or requiring non-resident hunters to pay for licenses, were a kind of contagion. This epidemic characteristic of legislations in the unsettled era of pre- and post-civil war times has likely been noted and thoroughly explored by scholars of law. (?) Or maybe my education gave me an epidemiology hammer, so every nuance I observe takes the shape of a nail. (Click here to return to your regularly scheduled paragraph.)

6. I want to acknowledge a glaring omission in my Mallard timeline—the entirety of the US Civil War. The Mallard story passes through the Civil War, of course, but I am not the right person to tell that part of history. I am not equipped to avoid all of the pitfalls and wrong turns in the Confederate branches of the Mallard mine. To be a reliable narrator surrounded by unreliable texts. Instead, I’m taking a coward’s deliberate leap over those years. Even so, lingering divisions between northern and southern states rise up throughout the legislative literatures of post-Civil War years. Such as in the excerpt that prompted this footnote. I’m including some of the indicators of ongoing division, in this series, in case some better-suited writer should wish to pick up those threads and go where I dared not. (Click here to return to your regularly scheduled paragraph.)

7. My aversion to such incentives was not shared by the US Department of Agriculture’s Biological Survey. At least, not in 1907. Thus the following: “In 1858 the example of Maine was followed in New Hampshire by the passage of a law authorizing the selectmen or municipal authorities to appoint fish wardens. The compensation of these officers consisted of one-half of the fines resulting from prosecutions instituted by them, an incentive to vigilance still employed in many states” (Williams, p. 12).

That said, the writer later criticized states that paid officers’ solely through incentives: “The meager compensation resulting from the percentage of fines secured sometimes allowed deputy wardens is hardly sufficient to enlist the services of active men…” (Williams, p. 26).

And even later: “In the early history of the movement for game protection the only provision considered feasible for payment of officers charged with the duty of enforcing game laws was an allowance of whole or part of the fines. A system maintained on such an unsatisfactory and unstable basis, however, accomplished almost nothing, and the advocates of better protection set about to devise a more satisfactory means” (Williams, p. 24). (Click here to return to your regularly scheduled paragraph.)

Bonus Earworm: If you are of a certain generation, you already have a song stuck in your head after reading the final section of this post. If you are younger and haven’t encountered this particular earworm, here’s the YouTube link for Brewer & Shipley’s “One Toke Over the Line”.

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References

Beagle, P. S. (1968). The last unicorn. Ballantine Books, Inc.

California Legislature (1852). The Statutes of California, passed at the third session of the Legislature, begun on the fifth day of January, 1852, and ended on the fourth day of May, 1852, at the cities of Vallejo and Sacramento. G. K. Fitch & Co., and V. E. Geiger & Co., State Printers. https://babel.hathitrust.org/cgi/pt?id=uc1.b4159816&seq=143&q1=mallard

General Assembly of Virginia (1841). Acts of the General Assembly of Virginia passed at the session commencing 1st December 1840, and ending 22d March 1841, in the sixty-fifth year of the Commonwealth. Samuel Shepherd, Printer to the Commonwealth. https://babel.hathitrust.org/cgi/pt?id=osu.32437123258960&seq=92&q1=fowl

Magner v. The People, 97 Ill. 320 (1881). https://www.courtlistener.com/opinion/7057357/magner-v-people/pdf/

Maryland General Assembly (1880). Laws of the state of Maryland made and passed at a session of the General Assembly begun and held at the city of Annapolis on the seventh day of January, 1880, and ended on the sixth day of April, 1880. Wm. T. Inglehart & Co., State Printers. https://msa.maryland.gov/megafile/msa/speccol/sc2900/sc2908/000001/000395/html/am395–1.html

Maryland General Assembly (1888). The Maryland Code, Public and local laws: Volume 1. King Bros., Printers and Publishers. https://msa.maryland.gov/megafile/msa/speccol/sc2900/sc2908/000001/000390/html/am390p–1.html

Maryland General Assembly (1916). Laws of the state of Maryland made and passed at the session of the General Assembly made and held at the city of Annapolis of the fifth day of January, 1916, and ended on the third day of April, 1916. King Bros., State Printers. https://msa.maryland.gov/megafile/msa/speccol/sc2900/sc2908/000001/000534/html/am534–1.html

Maryland General Assembly (1927). Laws of the state of Maryland made and passed at the session of the General Assembly made and held at the city of Annapolis on the fifth day of January and ending on the fourth day of April, 1927. King Bros., Inc., State Printers https://msa.maryland.gov/megafile/msa/speccol/sc2900/sc2908/000001/000569/html/am569–1.html

Maryland General Assembly (1941). Laws of the state of Maryland made and passed at the session of the General Assembly begun and held at the city of Annapolis on the first day of January, 1941, and ending on the thirty-first day of March, 1941. King Bros., Inc., State Printers https://msa.maryland.gov/megafile/msa/speccol/sc2900/sc2908/000001/000582/html/am582–1.html

Massachusetts General Court (1739). Acts and laws passed by the Great and General Court of Assembly of His Majesty’s province of the Massachussetts-Bay in New-England, begun and held at Boston, upon Wednesday the thirtieth day of May, 1739. John Draper, Printer to His Excellency the Governour and Council. https://archive.org/details/bim_eighteenth-century_acts-and-laws-passed-by-_massachusetts_1739_0/page/n1/mode/2up?q=deer

McKinley, R. (1988). The outlaws of Sherwood. [Kindle version]. Open Road Integrated Media. https://www.amazon.com/Outlaws-Sherwood-Robin-McKinley-ebook/dp/B00OGWASB4/ref=tmm_kin_swatch_0

Welton v. The State of Missouri, 91 U.S. 275 (1876). https://www.govinfo.gov/content/pkg/USREPORTS-91/pdf/USREPORTS-91-275.pdf

Williams, R. W. (1907). Game commissioners and wardens: Their appointment, powers, and duties. Government Printing Office. https://babel.hathitrust.org/cgi/pt?id=ufl1.ark:/13960/t43r22q5t&seq=15