"Tomko was charged with unlawful taking of a migratory waterfowl, a misdemeanor violation of the Illinois Conservation Code. "
If I were him, I'd challenge "migratory."
Mrs VS
Wonder if he could make the state prove, the said bird migrated. I have seen some who never leave their area. If there is plenty of food for them they will stay put.
Bingo. Don't know about his part of the world, but there are many, many non-migratory Canada geese in these parts, these days.