Breaking clays at distances of 35 - 45 yards or longer with cylinder or skeet-in chokes is a lot easier to do than to put a live bird on the ground at the same distances with the same chokes.
Full choke has its limits too and too many wild game shooters over-extend their gun's limit both with full choke as well as with cylinder. Use whichever choke, or lack thereof, in clays games but for live birds, common sense must rule.