The Outdoor Journal

Holland vs. Missouri – Part 2

Last week, we left this story with the passage of the Migratory Bird Treaty Act of 1918 and the refusal of some to acknowledge the federal government’s authority to prohibit the shooting of non-game birds and restrict the hunting of ducks, geese, and other waterfowl. With the passage of this law, the federal government could now protect migratory birds of all kinds. The test of whether or not the law would stick would come in the spring of 1919, when the migrations headed north.

By 1919, the Missouri Legislature had passed a bill instructing Missouri Attorney General Frank McAllister to defend any Missouri resident arrested by federal wardens. The Civil War was not that far in the past, and states’ rights passions still ran high in Missouri and elsewhere.