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Because the Michigan Audobon Society lobbied for it in 1931. The bird is very common in Michigan, and well known. It was passed as a House Resolution, not an actual law.
Three years later, it was discovered that the Kirtland's Warbler is unique to Michigan. It summers in Northern Michigan, and winters in the Bahamas. Sounds like a smart bird to me.
There is a push from the Michigan Audobon Society now to make the Kirtland Warbler the official state bird of Michigan.
Links:
http://en.wikipedia.org/wiki/Kirtland%27s_Warbler
http://www.netstate.com/states/symb/birds/mi_american_robin.htm
http://www.michiganaudubon.org/state_bird/state_bird.html
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The American Robin was adopted as the official Connecticut State Bird by the General Assembly in 1943. The white oak (Quercus alba) was adopted as the official Connecticut State Tree on April 16, 1947.
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