While I can think of no fitter setting for a symposium on this important topic, it must be admitted that geographically speaking, Missouri v. Holland disappoints. One thrills to the prospect of a divisive dispute between the State of Missouri and a province of the Netherlands - perhaps a sub-national compact on flood control gone sour? It quickly becomes apparent, though, that "Holland" is merely a lower-level federal official. And Missouri's particulars play a limited role in the case, as suggested by the fact that Kansas came to its side in the Supreme Court proceedings. Those who are not students of American history, or at least sports fans, may not appreciate the rarity and generosity of Kansas' gesture. Yet Missourians were, of course, front and center in the case. Ray Holland, the federal game warden, roamed Missouri and several neighboring states in pursuit of lawbreakers. Frank McAllister, Missouri's Attorney General, was an inveterate duck hunter and committed opponent of the reenacted federal ban on spring shooting who appears to have been on bad terms with Holland. Holland, hearing rumors that McAllister was encouraging others to break the law, apprehended the Attorney General and four friends while they were hunting near Nevada, Missouri; McAllister, found with a bag of seventy-six ducks, reportedly compounded his problems by giving a false name. He was prosecuted and fined, and in retaliation sought to enjoin the federal law on constitutional grounds. The proceedings ultimately generated Missouri v. Holland and victory for Holland - probably a particularly bitter pill for McAllister to swallow, given that he himself had argued the case on behalf of Missouri.

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