Radtke v. U.S. Bureau of Customs & Border Protection

CourtDistrict Court, District of Columbia
DecidedNovember 15, 2022
DocketCivil Action No. 2017-2412
StatusPublished

This text of Radtke v. U.S. Bureau of Customs & Border Protection (Radtke v. U.S. Bureau of Customs & Border Protection) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Radtke v. U.S. Bureau of Customs & Border Protection, (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CAPTAIN PAUL RADTKE, et al.,

Plaintiffs,

v. Civil Action No. 17-cv-2412 (TSC) U.S. BUREAU OF CUSTOMS & BORDER PROTECTION, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiffs Captain Paul Radtke, Offshore Marine Service Association, and Shipbuilders

Council of America have sued the Bureau of Customs and Border Protection (“CBP”) and its

Acting Commissioner Kevin K. McAleenan. Plaintiffs allege that Defendants have violated the

Administrative Procedure Act (“APA”) through a string of letter rulings incorrectly interpreting

the Jones Act and subsequent decisions not to revoke those letter rulings. ECF No. 1, Compl.,

¶¶ 1-2, 5. Defendants moved for judgment on the pleadings pursuant to Federal Rule of Civil

Procedure 12(c). ECF No. 18 (“Def. MJP”). Plaintiffs opposed and later moved for leave to

amend their complaint. ECF No. 35 (“Pl. Mot. for Leave”). For the reasons below, the court

will GRANT Plaintiffs’ motion for leave to amend and DENY without prejudice Defendants’

motion for judgment on the pleadings as moot.

I. BACKGROUND

A. Statutory Scheme

CBP is responsible for interpreting and enforcing Section 27 of the Merchant Marine Act

of 1920, commonly known as the Jones Act, 46 U.S.C. § 55102, which governs the

Page 1 of 12 transportation of merchandise between points in the United States—also known as “coastwise

transportation.” The Act requires that coastwise transportation be performed only by vessels

flagged, owned, built, and crewed by Americans—often termed “Jones Act qualified vessels.”

See 46 U.S.C. § 55102(b).

Pursuant to its general enforcement authority, CBP may issue interpretive “letter rulings”

applying the Jones Act prospectively to individual transactions. See 19 U.S.C. §§ 1502, 1625(a);

United States v. Mead Corp., 533 U.S. 218, 234 (2001). Letter rulings are intended to preview

for “importers and other interested persons” CBP’s view of a transaction before it is undertaken

and completed. 19 C.F.R. § 177.1(a)(1). Generally, CBP only issues a letter ruling when

requested by a “person who . . . has a direct and demonstrable interest in the question or

questions presented in the ruling request,” id. § 177.1(c), when the prospective transaction is not

“essentially hypothetical in nature,” id. § 177.7(a), and when issuing a letter ruling would not be

“contrary to the sound administration of the Customs and related laws,” id. Once issued,

however, a letter ruling constitutes CBP’s “official position” on “the particular transaction or

issue described therein and is binding on all Customs Service personnel.” Id. § 177.9(a).

By law, CBP must publish a letter ruling within 90 days of its issuance. 19 U.S.C.

§ 1625(a). Any “person may appeal an adverse interpretive ruling . . . to a higher level of

authority within the Customs Service for de novo review,” and CBP must decide the appeal

within 60 days. Id. § 1625(b).

While CBP may issue letter rulings without adversarial proceedings or notice and

comment, the Jones Act imposes special procedures for changing the rulings. If CBP proposes

an interpretive rule or decision that would “(1) modify . . . or revoke a prior interpretive ruling or

decision which has been in effect for at least 60 days; or (2) “have the effect of modifying the

Page 2 of 12 treatment previously accorded by the Customs Service to substantially identical transactions,”

CBP must provide a notice and comment period. Id. § 1625(c). “After consideration of any

comments received,” CBP must “publish a final ruling or decision” no later than 30 days after

the close of the notice and comment period. Id.

B. Plaintiffs’ Administrative Challenges

Plaintiffs are two associations—the Offshore Marine Service Association (OMSA) and

Shipbuilders Council of America (SCA)—and Captain Paul Radtke, who holds a U.S. Coast

Guard vessel operating license. Compl. ¶¶ 6-8. Plaintiffs or their members build, own, or

operate Jones Act qualified vessels. Id. Plaintiffs identify three ways in which CBP violated the

APA and caused them actionable harm.

First, Plaintiffs challenge CBP’s issuance of and failure to revoke twenty-five letter

rulings dating as far back as 1976. They claim these letter rulings collectively departed from the

Jones Act’s requirements by “permitting foreign vessels to transport merchandise between U.S.

points if they also engage in ancillary activities that are not regulated by the Jones Act,” id.

¶¶ 33-35, and “improperly narrow[ing] the definition of ‘merchandise’ that must be transported

by Jones Act,” id. ¶¶ 36-41. In 2009, and again in 2017, CBP initiated § 1625(c) proceedings

that proposed to revoke or modify some or all the allegedly unlawful letter rulings. Id. ¶¶ 43-44,

50-63. In both instances, however, CBP ultimately decided to withdraw those proposals and

make no changes after the close of the notice and comment periods. Id. ¶¶ 45, 66. After CBP

withdrew the proposals in 2017, OMSA sent a letter to Kevin K. McAleenan purporting to

“appeal, pursuant to 19 U.S.C. § 1625(b),” that decision. Id. ¶ 68; id. Exh. E, ECF No. 1-5, at 1-

2. Plaintiffs contend that CBP never responded to the letter. Id. ¶ 69. Accordingly, the

Complaint asserts that the twenty-five letter rulings, as well as CBP’s 2017 decision not to

Page 3 of 12 revoke them and failure to respond to OMSA’s appeal, were all “arbitrary, capricious, and

abuses of discretion, and contrary to law.” Id. ¶ 84.

Second, Plaintiffs object to CBP’s denial of OMSA’s request for a letter ruling

concerning decommissioning activities. An oil rig operator can abandon an offshore well in a

process called decommissioning, during which the operator will often use vessels to remove any

remaining installations or facilities before plugging the well. Compl. ¶¶ 86-87. In early 2016,

OMSA sought a letter ruling confirming that the Jones Act governed foreign vessels transporting

merchandise for decommissioning activities. Id. ¶ 89. CBP denied OMSA’s request, stating that

it was “hypothetical.” Id. ¶ 90. The next year, OMSA purported to “appeal, pursuant to 19

U.S.C. § 1625(b),” that denial along with the 2017 withdrawal. Id. ¶ 91; id. Exh. E, ECF No. 1-

5, at 1-2. The Complaint contends that both CBP’s denial of the request for a letter ruling, as

well as its failure to respond to the appeal letter, are “arbitrary, capricious, an abuse of discretion,

and contrary to law.” Id. ¶¶ 92-93.

Finally, Plaintiffs take issue with a 2012 letter ruling regarding the transportation of

“nodes”—devices for measuring seismic data on the Outer Continental Shelf. In that letter

ruling, CBP determined that if a foreign vessel transporting nodes qualified under the foreign

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