Whites Landing Fisheries, Inc. v. State of Ohio

CourtDistrict Court, N.D. Ohio
DecidedApril 17, 2025
Docket3:24-cv-01371
StatusUnknown

This text of Whites Landing Fisheries, Inc. v. State of Ohio (Whites Landing Fisheries, Inc. v. State of Ohio) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Whites Landing Fisheries, Inc. v. State of Ohio, (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION

White’s Landing Fisheries, Inc., et al., Case No. 3:24-cv-01371 Plaintiffs, Judge James G. Carr v.

State of Ohio, Department of Natural Resources Division of Wildlife, et al., ORDER

Defendants.

Pending is the Motion to Dismiss of Defendants, the State of Ohio, Department of Natural Resources (ODNR), it’s Director, Mary Mertz, and Division Chief, Kendra Wecker (State Defendants). Also named as Defendants are the United States of America, Department of Interior, Fish & Wildlife Services (Dep’t. of Interior), and the Secretary of the Interior, Deb Haaland (Federal Defendants). (Doc. 7). Plaintiffs, Whites Landing Fisheries, Inc., a Sandusky, Ohio commercial fishery, and its owner, Dean Koch, filed their Response. (Doc. 11). And Defendants filed a Reply. (Doc. 12). Plaintiffs claim that ODNR, the Dep’t of Interior, and the respective department heads, whom Plaintiffs sue in their official and individual capacities, violated their rights under the Ohio and U.S. Constitutions. (Doc. 1, PgID 4-8). Plaintiffs also allege breach of fiduciary duty and civil conspiracy as secondary causes of action. (Id. at 8-9). The State Defendants have filed their Motion under 12(b)(1) – asserting lack of jurisdiction – and 12(b)(6) – failure to state a claim. For the reasons below, I grant the Defendants’ Motion and dismiss this case as to all Defendants. Background The Dep’t of Interior’s Fish and Wildlife Service has delegated management of fishery resources in the Great Lakes to the Great Lakes Fisheries Commission. The Commission was formed under the Great Lakes Fishery Act of 1956, 16 U.S.C. §§ 931, et seq.. The membership consists of U.S. States and Canadian Provinces bordering the Great Lakes. The Commission’s role is advisory – primarily to facilitate research and make recommendations. It has no regulatory authority. 16 U.S.C. § 933. Regulation is left to the members, such as the State of Ohio. See Ohio Rev. Code §§ 1501,

1533 and Ohio Admin. Code Chapter 1501:31. ODNR is tasked with developing rules and procedures for fishing license allocations. Ohio Rev. Code §§ 1533.341 et seq., 16 U.S.C. § 939b. And its Division of Wildlife allocates quotas of game and fish as determined by the Great Lakes Fisheries Commission. Ohio Rev. Code § 1501.02. Provisions of Ohio Rev. Code Chapter 1531 bestow the Division of Wildlife Chief with authority to control all matters relating to the management of wild animals and fish and to adopt, amend, or rescind rules for such purpose. §§ 1531.06(B)(1), (2), 1531.09. The Chief may also limit the number and type of commercial fishing licenses. § 1533.342. In doing so, she must consider various factors, including “data relating to the protection, preservation, management, and utilization of fish species….” § 1533.342(C). The Chief also has the statutory authority to fix the species,

weight, number, and size of fish to be taken. § 1531.342 (D)(1).1 Ohio law also limits the transferability of fishing licenses. Ohio. Rev. Code § 1533.36. Only commercial licenses may be transferred, and this is even limited to the type of commercial fishing

1 Ohio regulates the amount of yellow perch fishermen may catch in Lake Erie. Ohio Admin. Code 1501:31- 3-12 “Quota management system for Lake Erie fishes.” The state has divided the Lake into perch management units, which are the geographic areas by which yellow perch quotas are allocated as established by the Lake Erie Committee of the Fishery Commission. Ohio Admin. Code §1501:31-1-02(ooo). gear for which the original license was issued. § 1533.36(b)(3). And the Division of Wildlife Chief, with the Director’s approval, “shall determine if any quota species of fish are transferable with the transferred license.” § 1533.36(b)(2). Discussion The rule at issue, Ohio Adm. Code 1501:31-3-12, was first enacted on January 2, 1996, and was most recently amended on January 1, 2023. This rule establishes the authority of the Division of Wildlife Chief to set quotas of catchable fish based on the unit areas and whether the fishing is

considered sport or commercial. The intended purpose of the rule is to “prevent over exploitation” of fish species and determine the “maximum allowable annual taking between and within the sport and commercial fisheries.” See Ohio Rev. Code § 1533.341. Plaintiffs challenge the limitations Defendants have placed on the numbers and the method of fishing used by commercial fisheries. According to the parties, the January 2023 revisions eliminated “seine” fishing2 as a way to catch yellow perch. The quotas are now allocated to trap nets,3 which is another type of commercial fishing. The rule allows trap net license holders to transfer perch quotas to other trap net licensees, but not to seine license holders.4 Among other contentions, Plaintiffs, who wish to continue seine fishing, argue these restrictions involve an unlawful taking of property under the Fifth and Fourteenth Amendments.

The State Defendants

2 Seine is a type of fishing process using a large vertical net held up by buoys and weighted down at the bottom. The net snares large amounts of fish, making it difficult to limit the limit the type of fish caught. https://cfs.osu.edu/archives/collections/lake-erie/seining.

3 Trap fishing utilizes a net structure, which is placed at a right angle to the suspected path of traveling fish. When fish confront a trap net, they turn and swim along it and get trapped in boxes. https://cfs.osu.edu/archives/collections/lake-erie/trap-netting.

4 Plaintiffs also reference rule changes banning commercial fishing of walleye in 1980. (Doc. 1, PgID 5). I disregard those allegations as time barred. McNamara v. City of Rittman, 473 F.3d 533 (6th Cir. 2007). 1. The Plaintiffs’ claims under the Takings Clause fail as a matter of law. The Takings Clause of the Fifth Amendment to the United States Constitution provides that private property shall not “be taken for public use, without just compensation.” This clause applies to the individual states by virtue of the Fourteenth Amendment. See Barber v. Charter Twp. of Springfield, Michigan, 31 F.4th 382, 387 (6th Cir. 2022). Federal courts have established a two-part test to determine whether government actions amount to a taking of property under the Fifth Amendment. First, a court must determine whether

the plaintiff “has established a cognizable property interest.” Coalition for Gov't Procurement v. Fed. Prison Indus., Inc., 365 F.3d 435, 481 (6th Cir. 2004). Second, “where a cognizable property interest is implicated, the court must consider whether a taking occurred.” Puckett v. Lexington- Fayette Urb. Cnty. Gov't, 833 F.3d 590, 609 (6th Cir. 2016).

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