North Carolina wildlife management programs should feel the impact of Hughes v. Oklahoma. The basis of North Carolina's wildlife regulations and caselaw is state ownership. Since Hughes overrules Geer v. Connecticut, North Carolina - to be addressed in the conclusion - will need to follow a new theory espousing more federal involvement in state wildlife programs.
Susan Morrison Umstead, Constitutional Law - State's Interest in Wild Animals, 2 Campbell L. Rev. 151 (1980).