Miles v. Virginia Marine Resources Commission

54 Va. Cir. 325
CourtAccomack County Circuit Court
DecidedDecember 28, 2000
DocketCase No. (Chancery) 00CH005
StatusPublished

This text of 54 Va. Cir. 325 (Miles v. Virginia Marine Resources Commission) is published on Counsel Stack Legal Research, covering Accomack County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miles v. Virginia Marine Resources Commission, 54 Va. Cir. 325 (Va. Super. Ct. 2000).

Opinion

BY JUDGE GLEN A. TYLER

The Court must decide in this case whether the Virginia Marine Resources Commission (VMRC or Commission) has unfairly reduced the number of peeler pots that a peeler crab fisherman may use from 400 pots to 300 pots. The appellants (Petitioners) allege that the VMRC’s regulation of the blue crab fisheiy has, by such reduction, created a burden upon the peeler crab segment of the fishery without an equitable sharing of the burden by the hard crab segment of the blue crab fisheiy. They argue that the VMRC has, by piecemeal regulation in 4 VAC 20-270-50, Virginia Administrative Code, violated the provisions of an enabling statute, Va. Code Ann. § 28.2-203 (1997 Repl. Vol.), and that this Court should vacate the offending amendment of the regulation and remand the matter to the VMRC for a more even handed sharing of the burden by all of the blue crab fishery.

The respondent argues that the amendment of its regulation, reducing the number of permitted peeler pots, is reasonable because it is in keeping with the Commission’s established Blue Crab Fisheiy Management Plan and alleviates an inequitable advantage gained by peeler potters in recent years in the blue crab fisheiy.

Because there may be those who will read this Opinion who are unfamiliar with the subject, it is appropriate to explain that which is well [326]*326known to all Chesapeake Bay watermen and to most people who live on the Eastern Shore, mainland or islands.

A mature male Atlantic blue crab is called a “jimmy.” A mature female is a “sook” and an immature female is a “she-crab” or “lady crab.” When a she-crab sheds her shell (external skeleton) for the last time, out of many times in her life, she becomes a sook. A blue crab grows by shedding its bony shell, which is called moulting, immediately after which it is very soft and has increased in size by approximately one-third. This very soft stage lasts only about half a day, if the crab is in the water, and it gradually hardens and is fully hard again in approximately two or three days.

Male blue crabs mate with females immediately after the females shed their shells. Females are attracted to males for several days prior to their last moult. During the days prior to their last moulting, female crabs are developing a soft second skin underneath their shells, and they are called “peelers.” An experienced waterman can identify peelers by examining their back fins, looking for a telltale pinkish fringe. The subject is fully explained for the layman by William W. Warner in his book, Beautiful Swimmers (1976).

There are various devices and methods for catching blue crabs. Among the devices are crab pots, which are basket-like devices used as traps (not to be confused with “crab traps” which are devices different from pots). The pot is usually made of galvanized or plastic-coated wire mesh, which the uninitiated landman would laughably call chicken wire. The mesh size is as to certain types of pots regulated by law. Va. Code Ann. §§ 28.2-701,28.2-705 (2000 Cum. Supp.). A pot is approximately 24 inches wide and 20 inches deep with openings for crabs to enter and from which they cannot escape. The Code of Virginia provides definitions as follows:

“Crab pot” means a device made of wire or thread net used to catch crabs.
“Peeler crab” [means] ... a crab that has a soft shell fully developed under the hard shell, or a crab on which there is a pink or white line or rim on the edge of that part of the back fin next to the outer section of this fin.
“Peeler pot” means a wire mesh pot baited with only live adult male (jimmy) blue crabs.1

[327]*327Va. Code Ann. § 28.2-700 (1997 Repl. Vol.).

The record in this case consists of a very large volume of documents. They are primarily the minutes of the meetings of the VMRC, together with exhibits, charts, public hearing records, and scientific reports. Rather than filling this Opinion with a plethora of footnotes, the record will be referred to generally and identified more specifically by the context.

At least as early as 1994, the minutes of the Commission reveal that total licensed peeler crab pots should be reduced in number in order to conserve crabs and thus promote the economic well-being of the blue crab fishery. There was some discussion then about the matter being an actual emergency because of overfishing specifically by peeler potters. The Commission concluded that an emergency did not then exist but that crabs were in decline. Therefore, the Commission commenced a comprehensive study of the crab industry with an eye towards correcting shortages in the supply of crabs. Significantly, discussion materials circulated to the Commission in 1994 showed that commercial crabbers then typically used 200 peeler pots per person, and such discussions included a suggested cap at that number.

Much scientific study and sampling ensued and empirical evidence was gathered from the commercial crab industry over a lengthy period of time.

At its meeting on October 25,1994, the Commission adopted a blue crab management plan that included as a separate part, among seven parts, a specific limitation upon the number of peeler crab pots that would be permitted to a crab fisherman. The limitation was 200 until June 30 each year and 400 thereafter during the year, commencing in 1995. There was no separate adjustment of hard crab pots for fishermen in the hard crab segment of the crab fishery. There was no indication in the minutes that anyone thought this regulation of peeler pots was a “piecemeal” regulation or one aimed unfairly at a sub-category of crab fisherman.

At the end of the crab fishing season for the year 1995, the Virginia Institute of Marine Science (VIMS) reported to the VMRC on the status of the blue crab stock. Its summary conclusion was that effective management was needed and that management should be based upon a proportional harvest of the potential spawning stock by each segment of the fishery, thus reflecting their assessment of the previous year’s study as well.

Then, on Januaiy 23, 1996, a veiy thorough scientific presentation was made to the Commission in addition to extensive information being received from members of the commercial industry. The Commission concluded by increasing its seven-point Blue Crab Fisheiy Management Plan to an eleven-point Plan, including, among other things, adjusting the limits on peeler pots to 300 in tributaries of the Bay and 500 in the mainstream of the Bay (later [328]*328adjusted to 400 in all waters). In addition, the Commission began a program of limiting entry by persons into the peeler pot fishery in the 1996 season as a further crab conservation measure and as a further protection of fishermen previously in the industry. This latter management action would soon prove to burden the Commission and its staff with a large increase in the number of persons applying for and receiving peeler pot licenses. The new applicants, the record discloses, intended to protect their options to preserve “potential” effort for the future rather than actually increase their immediate efforts at catching crabs.

The most significant revelations occurred in the Spring of 1999. There had been an eleven-point plan in place regulating the blue crab fishery, the seven-point plan from 1994 and four additional points from 1996, which included the limitation on peeler pots described above.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Minnesota v. Clover Leaf Creamery Co.
449 U.S. 456 (Supreme Court, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
54 Va. Cir. 325, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miles-v-virginia-marine-resources-commission-vaccaccomack-2000.