Geer v. Connecticut, 161 U.S. 519 (1896) - Initially, the Supreme Court dealt with wildlife cases that focused mainly on the authority of States to regulate the taking of fish, game, and shellfish. In a series of cases in the 19th century, the Court determined the States did have authority to control and regulate wildlife and went so far as to declare, in Geer v. Connecticut, in 1896 that there was a "common property in game" that the State had the authority to regulate "as a trust for the benefit of the people." In essence, this case "articulated a general theory of State 'ownership' of wildlife," which the States later relied upon to challenge the validity of Federal wildlife-regulation efforts. The State ownership doctrine was used only once by the Court. In The Abby Dodge, a 1912 decision, the Court barred Federal regulation of the harvest of sponges in Florida's territorial waters on the ground that the regulation of such harvest was exclusively within the power of the State.