George Sutherland, Hunt v. United States (278 U.S. 96…
“ During the last few years deer on these reserves have increased in such large numbers that the forage is insufficient for their subsistence. The result has been that these deer have greatly injured the lands in the reserves by overbrowsing upon and killing valuable young trees, shrubs, bushes, and forage plants. Thousands of deer have died because of insufficient forage. Attempts were made under the direction of the Secretary of Agriculture to remove some of the deer from the reserves to other lands, but these entirely failed, as did other means. ”
