Guindon v. Pritzker
United States District Court for the District of Columbia
31 F. Supp. 3d 169 (2014)
- Written by Liz Nakamura, JD
Facts
The Gulf Regional Fisheries Management Council (Council) managed the Gulf of Mexico fishery under the authority of the National Marine Fisheries Service (NMFS) (defendant). The Council created fishery management plans (FMPs), which included setting annual catch quotas for commercial and recreational fishermen to prevent overfishing. Red snapper was designated as overfished and was subject to a strict quota that was allocated 51-49 between commercial and recreational fishermen. The commercial quota was enforced through strict monitoring and individual vessel quotas. The recreational quota was enforced through fixed recreational fishing seasons and by checking recreational catch totals using dockside intercepts and phone surveys. From 2008 to 2012, recreational fishermen exceeded their red snapper quota. In 2013, the Council proposed increasing the recreational red snapper quota. Subsequently, the Council received landing data indicating that 2013 recreational landings had already exceeded the quota, even with the proposed increase. The 2013 landing data was collected using a more comprehensive sampling method than in prior years. Regardless, NMFS reopened the recreational red snapper season in the fall, thereby allowing additional recreational landings above the annual quota. Keith Guindon (plaintiff), a commercial fisherman, challenged the NMFS’s red snapper recreational fishing regulations, arguing that the regulations violated the Magnuson–Stevens Fishery Conservation and Management Act (Magnuson–Stevens Act) by failing to prevent retention of fish caught over the recreational quota. NMFS countered, arguing that the new sampling methodology used in 2013 indicated that the quota should have been set higher and that it was inappropriate to punish recreational fishermen for violating artificially low quotas.
Rule of Law
Issue
Holding and Reasoning (Rothstein, J.)
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