Got a surprising answer from my local game warden recently. You want to get close to birds? You want to choose between several gobblers? Sneak into a roost site before daylight and watch the trees when the sun comes up. You will be able to kill your pick of birds, and shoot them right out of the trees before they even wake up.
Yes, thats right, it's legal to do in my state. But I don't know many people who do it that way.
I will admit that I have shot one out of a tree. But after 1 1/2 hours of calling and having the same bird answer on an extremely windy morning. I decided to go to the bird. After another 1/2 hour of belly crawling and slipping behind trees, I saw the large gobbler, pacing back and forth on a large oak limb. I figured I'd worked hard enough to deserve that bird and killed him. Sneaking in and killing a fully alert bird that is gobbling, seems different than shooting a sleepy bird from the roost.
Both require quite a bit of skill. I mean it's not easy to sneak into a roost site and get close enough to kill a turkey and it's definitely not easy to come within shotgun range of a fully alert and gobbling bird. It's legal so why not? I personally will stick to calling them in whenever possible. But is the bird I shot out of a tree considered a roosting bird? He's been gobbling for 2 hours and walking up and down a limb.