^^^ Same for WI.
My brother and I own 320 acres in NE WI, and even on a parcel that sized, a high shoulder shot is preferred. This last weekend, I wanted to try a 95 gr. Barnes TTSX load, in one of my 6.8 SPC chambered AR-15s. So on a doe, at about 60 yards, I did a vitals shot, just catching the back edge of the on-side front shoulder. On the shot, she took off running, with the on-side front shoulder hanging stiff and straight. She was dead, and didn't know it. But the issue arose, when she started heading to the thickest cedar swamp morass on our property. One doesn't walk through that, one crawls. So not wanting to drag the doe out of that, I pulled ahead, and went for a running spine shot. Should have done the high shoulder shot on the first one! On the second shot report, the deer disappeared, and the woods was quiet... So even if one is not near a property line, there may be good reason to do a high shoulder shot. That few inches of meat loss, won't be missed.
Oh for anyone interested, that 95 gr. Barnes TTSX is a hammer on deer! On the spine shot, I had about 4" of ground meat and bone, come out of the exit hole, when I skinned the doe. And the most I could find was a small grapefruit sized chunk of lungs...the rest was pulp. This carbine AR-15, is now my most favorite box blind gun, where quarters are tight.
Squeeze