In McKee v. Gratz, 260 U.S. 127, 43 S. Ct. 16, 67 L. Ed. 167 (1922), the Court observed: There is a plain distinction between mussels and game birds or freely moving fish, that may shift to another jurisdiction without regard to the will of land owner or State. . . . On the other hand it seems not unreasonable to say that mussels having a practically fixed habitat and little ability to move are as truly in the possession of the owner of the land in which they are sunk as would be a prehistoric boat discovered under ground or unknown property at the bottom of a canal. Id. at 135 Although the Court did not hold shellfish constitute part of the realty for purposes of the state statute at issue, id., the Court nevertheless concluded possession of mussels via ownership of the real property entitled the owner to damages for conversion by a trespasser. "We are slow to believe that there were public rights extending to the removal of mussels against the land owner's will." Id. at 136.