In mich, the dnr have to prove very little, in a case like this the dnr shows up to a harassment complaint and observes the subject cruising around on the property line barking like a dog, having never seen this before the officer concludes that this is not normal behavior at wich time he also concludes that this is likely intended to bother the hunter who made the complaint, the officer writes the ticket and its game over for the mad barker.
Since you really cant put a bark in an evidence bag I was assuming that the officer would be there to see it for him self at some point and that would be all the evidence needed.