I've no idea.
My wild guess is it's some ordinance on how one uses land/resources in a way that impacts the public at large. And that the plaintiff was making a claim that a bird belongs in this "public trust" so if you hurt a bird you're in violation.
But I'm no lawyer.
The Altamonte Windmill operators should counter sue 'cause the birds are striking the blades. Their remains effect the wind flow and reduce the electicity produced which prduces a real,albeit miniscule, loss of income!!!