I don’t think so. First off it would be unlikely that this would happen at least in the case of a commercial plane: birds generally fly under 5,000 feet while planes fly above this level. The most likely time then that a plane could crash into an eagle would be during take-off or landing, so the airport or strip it would be using would have to be within range of an eagle habitat. Airports purposely try to ward off many birds, specifically large birds, from living within their vicinity. Second off, if this did happen to occur by accident it wouldn’t fall under the statute that protects birds. The Eagle Protection act outlaws transportation, moving of, selling, bartering, importing or exporting eagles dead or alive, but it never mention anything about killing them, probably because the reasoning was if someone is going to kill an eagle it will be for the purpose of selling and transporting. Most people won’t just randomly go out looking for eagles, killing them, and leaving them in the spot where they died. Similarly I don’t think a plane would intentionally or carelessly hit eagles, because that could cause the plane to crash.
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