LA Shrimp Association v. Lutnick

Court of Appeals for the Fifth Circuit·Decided August 28, 2026·No. 25-30408·Unpublished

Opinion

United States Court of Appeals for the Fifth Circuit United States Court of Appeals ____________ Fifth Circuit

FILED

No. 25-30408 August 28, 2026

Lyle W. Cayce

Clerk

Louisiana Shrimp Association; John Brown; Larry Helmer, Jr.; Penny V. Zar,

Plaintiffs—Appellants,

versus

Howard Lutnick, Secretary, U.S. Department of Commerce, In his official capacity; National Marine Fisheries Service; Donald J. Trump, President of the United States, In his official capacity,

Defendants—Appellees.

Appeal from the United States District Court for the Eastern District of Louisiana USDC No. 2:24-CV-156

Before Elrod, Chief Judge, and Clement and Oldham, Circuit Judges. Jennifer Walker Elrod, Chief Judge: * In 2019, the National Marine Fisheries Service issued a rule requiring all skimmer-trawl vessels 40 feet and longer to use turtle-excluder devices, which allow sea turtles to escape from their nets. Plaintiffs—a commercial shrimping organization and three individuals active in the shrimping

*

This opinion is not designated for publication. See 5th Cir. R. 47.5.

No. 25-30408

industry—challenged the rule under the Administrative Procedure Act. On cross-motions for summary judgment, the district court upheld the 2019 Rule. We AFFIRM the district court’s grant of summary judgment to Defendants and denial of summary judgment to Plaintiffs.

I

A

The Endangered Species Act makes it unlawful to “take”—that is, “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect”— endangered and threatened species. 16 U.S.C. §§ 1532(19), 1538(a)(1)(B); see 50 C.F.R. § 223.205. The Act exempts from this prohibition certain takings that are “incidental” to lawful activity. See 16 U.S.C. § 1536(b)(4), (o)(2). It also gives the Secretary of Commerce authority to promulgate regulations to restrict takings of the relevant species. Id. § 1533(d). Federal agencies that take actions covered by the Endangered Species Act must “use the best scientific and commercial data available” to ensure that they are not likely to harm endangered or threatened species. Id. § 1536(a)(2).

B

In 1987, the National Marine Fisheries Service (NMFS) promulgated a rule intended to reduce incidental takings of several species of endangered and threatened sea turtles by shrimp trawler vessels. This rule required shrimp trawler vessels 25 feet and longer operating in offshore waters to use turtle-excluder devices (TEDs). Sea Turtle Conservation; Shrimp Trawling Requirements, 52 Fed. Reg. 24244, 24248 (June 29, 1987) (to be codified at 50 C.F.R. pts. 217, 222, 227). The agency had planned to apply the same requirement to all shrimping vessels, regardless of size and whether operating inshore or offshore. See generally Sea Turtle Conservation; Shrimp Trawal Requirements, 52 Fed. Reg. 6179 (proposed Mar. 2, 1987) (to be codified at 50 C.F.R. pts. 217, 222, 227). However, recognizing “the limited scientific

No. 25-30408

data on the incidental mortality of sea turtle[s] and TED effectiveness in certain areas, particularly inshore waters,” the 1987 Rule ultimately allowed smaller shrimp trawler vessels in offshore waters and all shrimp trawler vessels in inshore waters to instead comply with “tow-time restrictions”— i.e., limits on how long a vessel can tow its nets without checking for captured turtles. 52 Fed. Reg. at 24246, 24251–52.

Soon after, NMFS expanded its regulations in this area. In 1992, the agency eliminated the inshore–offshore distinction, generally requiring all shrimp trawler vessels to use TEDs year-round. Threatened Fish and Wildlife; Threatened Marine Reptiles; Revisions to Enhance and Facilitate Compliance With Sea Turtle Conservation Requirements Applicable to Shrimp Trawlers; Restrictions Applicable to Shrimp Trawlers and Other Fisheries, 57 Fed. Reg. 57348, 57351–52 (Dec. 4, 1992) (to be codified at 50 C.F.R. pts. 217, 227). However, NMFS still exempted certain types of inshore shrimp trawler vessels from the TED requirement, including skimmer-trawl vessels, 1 allowing them to continue abiding by tow-time restrictions. Id. at 57349, 57354. In 2003, NMFS modified its TED requirements to require larger escape-opening sizes.

In 2012, after a significant increase in sea-turtle strandings in the northern Gulf of America 2 and related litigation from environmental groups,

1 A skimmer-trawl vessel is a type of commercial shrimp trawler vessel commonly used in shallower, inshore waters. It pushes rigid, L-shaped or trapezoid frames with attached nets through the water, “skimming” the surface and mid-depths. See Sea Turtle Conservation; Shrimp Trawling Requirements, 81 Fed. Reg. 91097, 91098–99 (proposed Dec. 16, 2016) (to be codified at 50 C.F.R. pt. 223). Almost all skimmer-trawl vessels in the United States operate out of Louisiana; a much smaller number operate out of Mississippi, Alabama, North Carolina, and Florida.

2 On January 20, 2025, President Trump directed the Secretary of the Interior to rename the United States continental-shelf area formerly known as the Gulf of Mexico the “Gulf of America” and to update the Geographic Names Information System accordingly.

No. 25-30408

NMFS proposed an even more protective rule that would have eliminated alternative tow-time restrictions and required all skimmer-trawl, pusher- head-trawl, and wing-net vessels to use TEDs. See generally Sea Turtle Conservation; Shrimp Trawling Requirements, 77 Fed. Reg. 27411 (proposed May 10, 2012) (to be codified at 50 C.F.R. pt. 223). But NMFS withdrew this proposed rule in 2013, after discovering a flaw in the standard TED design that prevented smaller sea turtles—which are often encountered by shrimp trawler vessels operating in shallower, inshore waters—from escaping, thus defeating the purpose of the device. Sea Turtle Conservation; Shrimp Trawling Requirements, 78 Fed. Reg. 9024, 9025 (Feb. 7, 2013) (to be codified at 50 C.F.R. pt. 223). The withdrawal stated that the agency would “explore technological solutions to address the small turtle issue,” with the goal of gathering “sufficient information to evaluate a potential proposed rule that would be effective in reducing sea turtle bycatch in the inshore skimmer trawl fisheries in the near future.” Id. at 9026. NMFS also announced its intent to consult with experts to produce a report on “criteria to determine mortality in trawl fisheries.” Id.

From 2013 onward, NMFS tested new TED configurations and convened an expert workshop to develop national criteria for assessing post-interaction mortality for sea turtles captured in gear used by shrimp trawler vessels. Environmental groups again sued in 2015, urging NMFS to enact more restrictive regulations on shrimp trawler vessels.

Exec. Order No. 14172, § 4(b), 90 Fed. Reg. 8629, 8630 (Jan. 31, 2025). We use this federal designation, although documents in the administrative record from before 2025 use “Gulf of Mexico.”

No. 25-30408

C

In 2016, NMFS issued another proposed rule, which again proposed to eliminate alternative tow-time restrictions and require all skimmer-trawl, pusher-head-trawl, and wing-net vessels to use TEDs. Sea Turtle Conservation; Shrimp Trawling Requirements, 81 Fed. Reg. 91097, 91098, 91100 (proposed Dec. 16, 2016) (to be codified at 50 C.F.R. pt. 223). The 2016 Proposed Rule concluded that, in light of NMFS’s development of new TED configurations, difficulties in enforcing tow-time restrictions, changes in gear used by skimmer-trawl vessels, and changes in sea-turtle population, requiring TEDs for these types of shrimp trawler vessels was necessary and appropriate. Id. at 91098.

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