New England Fishermen's Stewardship Association v. Lutnick

CourtCourt of Appeals for the First Circuit
DecidedApril 30, 2026
Docket25-1213
StatusPublished

This text of New England Fishermen's Stewardship Association v. Lutnick (New England Fishermen's Stewardship Association v. Lutnick) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New England Fishermen's Stewardship Association v. Lutnick, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

Nos. 25-1212 25-1213

NEW ENGLAND FISHERMEN'S STEWARDSHIP ASSOCIATION,

Plaintiff, Appellant/Cross-Appellee,

JERRY LEEMAN,

Plaintiff,

v.

HOWARD LUTNICK, in the capacity of Secretary of Commerce; NATIONAL MARINE FISHERIES SERVICE; EMILY MENASHES, in the capacity of Acting Assistant Administrator for Fisheries at NMFS; SAMUEL D. RAUCH, III, in the capacity of Deputy Assistant Administrator for Regulatory Programs at NMFS,

Defendants, Appellees/Cross-Appellants.

APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE

[Hon. John A. Woodcock, Jr., U.S. District Judge]

Before

Aframe, Lynch, and Dunlap, Circuit Judges.

John M. Gore, with whom Donald F. McGahn, II, John Henry Thompson, Louis J. Capozzi, III, Julia Kazam, and Jones Day were on brief, for appellant New England Fishermen's Stewardship Association. Daniel Halainen, Attorney, U.S. Department of Justice, Environment and Natural Resources Division, with whom Adam R.F. Gustafson, Acting Assistant Attorney General, and Thekla Hansen-Young, Attorney, U.S. Department of Justice, Environment and Natural Resources Division, were on brief, for appellees Howard Lutnick, National Marine Fisheries Service, Emily Menashes, and Samuel D. Rauch, III.

J. Timothy Hobbs and K&L Gates LLP on brief for Seafood Harvesters of America, amicus curiae.

April 30, 2026 LYNCH, Circuit Judge. This appeal stems from a dispute

between the New England Fishermen's Stewardship Association

("Association"), the Secretary of Commerce ("Secretary"), and the

National Marine Fisheries Service ("NMFS") over the Framework

Adjustment 65 Final Rule and implementing regulations, which

affected the Association's members by reducing catch limits for

several species in the Northeast Multispecies Fishery Management

Plan. The Association here argues that the Framework Adjustment 65

Final Rule and implementing regulations must be invalidated under

the Appointments Clause of the U.S. Constitution because of the

involvement of the advisory New England Fishery Management

Council. We disagree and, on de novo review, hold the Association

is not entitled to relief.

I.

We summarize the Magnuson-Stevens Fishery Conservation

and Management Act's ("Act"), 16 U.S.C. § 1801 et seq., fishery

management scheme. We then describe the undisputed factual

background which is relevant to the Association's request for

injunctive and declaratory relief as to Framework Adjustment 65.

A. The Magnuson-Stevens Fishery Conservation and Management Act

The Act, the provisions of which govern this dispute,

states thirteen Congressional findings at 16 U.S.C. § 1801(a) that

explain its creation of a "national program for the conservation

- 3 - and management of the fishery1 resources of the United States,"

which Congress found "[wa]s necessary to prevent overfishing, to

rebuild overfished stocks, to insure conservation, to facilitate

long-term protection of essential fish habitats, and to realize

the full potential of the Nation's fishery resources." 16 U.S.C.

§ 1801(a)(6). Congress further found that while fisheries faced

threats of "increased fishing pressure, . . . inadequacy of

fishery resource conservation and management practices and

controls, [and] . . . habitat losses," id. § 1801(a)(2),

nonetheless fisheries are "finite but renewable" resources which

"can be conserved and maintained so as to provide optimum yields

on a continuing basis," "[i]f placed under sound management before

overfishing has caused irreversible effects," id. § 1801(a)(5).

At § 1801(b), Congress next stated its seven purposes in

passing the Act. One of these purposes explained the structure of

the fishery management program. Congress sought to "enable the

States, the fishing industry, consumer and environmental

organizations, and other interested persons to participate in, and

advise on, the establishment and administration of [fishery

management] plans [("FMPs")]" and to "take into account the social

and economic needs of the States." Id. § 1801(b)(5). To achieve

1 Fisheries are defined in relevant part as "stocks of fish which can be treated as a unit for purposes of conservation and management." 16 U.S.C. § 1802(13)(A).

- 4 - these purposes, the Act "establish[ed] Regional Fishery Management

Councils" and gave them a structured role of "prepar[ing],

monitoring, and revisi[ng] [FMPs]." Id.

An FMP sets out "the conservation and management

measures . . . necessary and appropriate for the conservation and

management of [a given] fishery, to prevent overfishing and rebuild

overfished stocks, and to protect, restore, and promote the

long-term health and stability of the fishery." Id.

§ 1853(a)(1)(A). Congress mandated that each FMP be "consistent

with the [ten] national standards for fishery conservation and

management." Id. § 1851(a). These national standards are "broadly

worded" and "can be in tension with one another." Lovgren v.

Locke, 701 F.3d 5, 32 (1st Cir. 2012). The national standards

require, for example, that the "[c]onservation and management

measures" in an FMP "shall prevent overfishing while achieving, on

a continuing basis, the optimum yield from each fishery for the

United States fishing industry," 16 U.S.C. § 1851(a)(1), while

also requiring FMPs to "take into account the importance of fishery

resources to fishing communities . . . [and] minimize adverse

economic impacts on such communities," id. § 1851(a)(8).

This structure furthers the seven policy objectives of

the Act set out in § 1801(c), including the objective:

to assure that the national fishery conservation and management program utilizes, and is based upon, the best scientific

- 5 - information available; involves, and is responsive to the needs of, interested and affected States and citizens; considers efficiency; draws upon Federal, State, and academic capabilities in carrying out research, administration, management, and enforcement; considers the effects of fishing on immature fish and encourages development of practical measures that minimize bycatch and avoid unnecessary waste of fish; and is workable and effective[.]

Id. § 1801(c)(3).

The Act mandates that the Secretary, who is responsible

for the Act's fishery management scheme, "establish advisory

guidelines (which shall not have the force and effect of law),

based on the national standards, to assist in the development of

fishery management plans." Id. § 1851(b). The Secretary has

delegated his authorities under the Act to the Under Secretary for

Oceans and Atmosphere at the National Oceanic and Atmospheric

Administration ("NOAA"), who has in turn delegated authority to

NOAA's Assistant Administrator for Fisheries, the official that

oversees NMFS ("NMFS Director"). NMFS administers the Act under

this delegation.

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