Rare bird. The Second Circuit has affirmed the conviction of Thomas Cullen, an internationally known professional falconer for violation of the the Wild Bird Conservation Act of 1992 Cullen was convicted of illegally importing some Black Sparrowhawks, a very rare bird indeed. Cullen tried to escape imprisonment by asserting a number of technical defenses, but to no avail.

The decision in United States v. Cullen can be found here.