Different states have different rules. Indiana, Tennessee, Illinois all have this rule. Kentucky doesn't count the fish you have in you freezer as part of the possession limit.
I don't know of anyone ever being busted for having over the limit in their freezer but, the law being the law, it is conceivable if someone had a beef with someone they could make a phone call and possibly cause a problem.
Doubtful that it would happen though.
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