Natural Resources Defense Council, Inc. v. Lutnick

United States Court of International Trade·Decided August 19, 2026·No. 24-00148·Published

Opinion

Slip Op. 26-

UNITED STATES COURT OF INTERNATIONAL TRADE

NATURAL RESOURCES DEFENSE COUNCIL, INC.; CENTER FOR BIOLOGICAL DIVERSITY; and ANIMAL WELFARE INSTITUTE,

Plaintiffs,

v.

HOWARD LUTNICK, in his official capacity as Secretary of Commerce; UNITED STATES DEPARTMENT OF COMMERCE; EUGENIO PIÑEIRO SOLER, in his official capacity as Assistant Administrator of the National Marine Fisheries Service; NATIONAL MARINE FISHERIES SERVICE; SCOTT BESSENT, in his official capacity as Secretary of the Treasury; UNITED STATES DEPARTMENT OF THE TREASURY; MARKWAYNE MULLIN, in Before: Judge Gary S. Katzmann his official capacity as Secretary of Homeland Court No. 24-00148

Security; and UNITED STATES DEPARTMENT OF HOMELAND SECURITY,

Defendants,

and

NATIONAL FISHERIES INSTITUTE, INC.; RESTAURANT LAW CENTER; PHILLIPS FOODS, INC.; HERON POINT SEAFOOD, LLC; NEWPORT INT’L OF TIERRA VERDE, INC.; 3FISH, INC.; HANDY SEAFOOD INC.; SHAW’S SOUTHERN BELLE FROZEN FOODS, INC.; SUPREME CRAB & SEAFOOD, INC.; CEBU PACIFIC LLC; BYRD INT’L INC.; AND CRUSTACEA SEAFOOD CO., INC.,

Defendant-Intervenors.

Court No. 24-00148 Page 2

OPINION AND ORDER

[ Plaintiffs’ motion to enforce the settlement agreement is denied as moot. ]

Dated: August 19, 2026

Sean M. Grammel, Anderson & Kreiger LLP, of Boston, MA, argued for Plaintiffs Natural Resources Defense Council, Inc.; Center for Biological Diversity, and Animal Welfare Institute. On the briefs were Christina S. Marshall, Mina S. Makarious, and Marissa C. Grenon Gutierrez, Anderson & Kreiger LLP, of Boston, MA; Sarah Uhlemann, Center for Biological Diversity, of Olympia, WA; and Stephen Zak Smith, Natural Resources Defense Council, of Bozeman, MT.

Brenna E. Jenny, Deputy Assistant Attorney General, Civil Division, U.S. Department of Justice, of Washington, D.C., argued for Defendants Howard Lutnick, in his official capacity as Secretary of Commerce; United States Department of Commerce; Eugenio Piñeiro Soler, in his official capacity as Assistant Administrator of The National Marine Fisheries Service; National Marine Fisheries Service; Scott Bessent, in his official capacity as Secretary of The Treasury; United States Department of The Treasury, Kristi Noem, in her official capacity as Secretary of Homeland Security, and United States Department of Homeland Security. 1 Also on the briefs were Brett A. Shumate, Assistant Attorney General, Patricia M. McCarthy, Director, and Agatha Koprowski, Trial Attorney. Of counsel on the briefs were Mark Hodor, Office of General Counsel, National Oceanic & Atmospheric Administration; Daniel Paisley, Office of General Counsel, U.S. Department of the Treasury; and Zachary Simmons, Office of the Chief Counsel, U.S. Customs & Border Protection.

Ashley Akers, Holland & Knight, LLP, of Washington, D.C., argued for Defendant-Intervenors National Fisheries Institute, Inc.; Restaurant Law Center; Phillips Foods, Inc.; Heron Point Seafood, LLC; Newport Int’l of Tierra Verde, Inc.; 3Fish, Inc.; Handy Seafood Inc.; Shaw’s Southern Belle Frozen Foods, Inc.; Supreme Crab & Seafood, Inc.; Cebu Pacific LLC; Byrd Int’l Inc.; and Crustacea Seafood Co., Inc. Also on the briefs were Rafe Petersen, Kamran Mohiuddin, and Maggie Pahl.

Katzmann, Judge: The court returns to the Marine Mammal Protection Act (“MMPA”) and to a stipulated settlement agreement for which the court has retained jurisdiction.

In 1972, Congress enacted the MMPA, Pub. L. No. 92-522, 86 Stat. 1027 (codified as amended at 16 U.S.C. § 1361 et seq.), to protect marine mammal species that “are, or may be, in danger of extinction or depletion as a result of man’s activities” from “diminish[ing] below their optimum sustainable population.” 16 U.S.C. § 1361(1)–(2). In recent years, the MMPA has been

1 Per USCIT Rule 25(d), named officials have been substituted to reflect the current officeholders.

Court No. 24-00148 Page 3

the basis for litigation and adjudication in this court for actions involving the vaquita, the world’s smallest porpoise on the verge of extinction, see Nat. Res. Def. Council, Inc. v. Ross, 44 CIT __, __, 456 F. Supp. 3d 1292, 1295 (2020) (and opinions noted therein); see also Ctr. for Bio. Diversity v. Haaland, 47 CIT __, __, 639 F. Supp. 3d 1355, 1363 (2023), and the MƗui dolphin, one of the world’s smallest dolphins also on the verge of extinction, see, e.g., Sea Shepherd N. Z. v. United States, 48 CIT __, 723 F. Supp. 3d 1374 (2024) (and opinions noted therein); MƗui & Hector’s Dolphin Defs. NZ Inc. v. Nat’l Marine Fisheries Serv., 49 CIT __, __, 799 F. Supp. 3d 1327, 1350 (2025).

Although invoked in recent litigation, the MMPA’s Import Provisions—intended to reduce bycatch associated with international commercial fishing operations—had, until recently, yet to be fully implemented since the MMPA’s 1972 enactment. See Nat’l Res. Defense Council, Inc. v. Lutnick, 49 CIT __, __, 774 F. Supp. 3d 1348, 1351 (2025). Plaintiffs Natural Resource Defense Council (“NRDC”), Center for Biological Diversity, and Animal Welfare Institute (collectively “Plaintiffs”) originally brought a challenge alleging that Defendants comprising various United States Departments and constituent agency and respective officials (collectively “the Government”) failed to implement the MMPA’s Import Provisions. See Compl., Aug. 8, 2024, ECF No. 1.

Spurred by the litigation and a settlement agreement in this case, the Import Provisions, 16 U.S.C. § 1371(a)(2), have been implemented for the first time since the MMPA’s enactment. See Implementation of Fish and Fish Product Import Provisions of the Marine Mammal Protection Act—Notification of Comparability Findings and Implementation of Import Restrictions; Certification of Admissibility for Certain Fish Products, 90 Fed. Reg. 42395, 42396 (Dep’t Com. Sep. 2, 2025) (“2025 Implementation of Import Provisions”). Since the beginning of this case, the

Court No. 24-00148 Page 4

Government has issued comparability findings for all harvesting nations and fisheries seeking to export fish and fish products to the United States (135 nations covering approximately 2,500 fisheries) and banned the importation of commercial fish or products from fish that have been caught with commercial fishing technology which results in the incidental kill or incidental serious injury of ocean mammals in excess of U.S. standards. 2 See id.; Implementation of Fish and Fish Product Import Provisions of the Marine Mammal Protection Action—Notification of Comparability Findings, 91 Fed. Reg. 25867, 25867–68 (Dep’t Com. May 12, 2026) (“2026 Implementation of Import Provisions”).

Following the Government’s subsequent issuance of comparability findings and implementation of related import bans, all parties now agree that no live controversy remains in this case. See Second Joint Status Report at 3, June 16, 2026, ECF No. 66. Accordingly, the court denies as moot Plaintiffs’ motion to enforce the settlement agreement in this case. See Mot. to Enforce Settlement Agreement, Dec. 12, 2025, ECF No. 40 (“Pls.’ Br.”); see also Stipulation of Dismissal at Attach. A, Jan. 16, 2025, ECF No. 29 (“NRDC Agreement”).

LEGAL BACKGROUND

Given the seriousness of the interests at stake, the court pauses to briefly recount the history of the MMPA and this litigation.

I. The Marine Mammal Protection Act As noted, in response to the threat that human activities pose to marine mammals, Congress

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