District 4 Lodge of the International Association of Machinists and Aerospace Workers Local Lodge 207 v. Raimondo

Summary

The First Circuit vacated a preliminary injunction that had blocked a seasonal closure of a 967-square-mile lobster fishing zone off Maine, designed to protect critically endangered North Atlantic right whales from entanglement in vertical buoy lines. The court held that the National Marine Fisheries Service did not act arbitrarily or capriciously under the Administrative Procedure Act by relying on statistical modeling to define the closure's time and place, even with imprecise inputs, and that the agency adequately explained its rejection of alternative measures. Applying the preliminary injunction standard, the court found plaintiffs unlikely to succeed on the merits and that Congress had placed a "heavy thumb on the whale-side of the equities' scale," making the balance of hardships and public interest favor the endangered species. The case underscores the broad deference afforded to agency factfinding and the weight given to statutory mandates to prevent extinction under the Endangered Species Act.

Holdings

1. The Agency did not act arbitrarily and capriciously. It relied on a peer-reviewed model, acknowledged data limitations, and acted under a statutory mandate to protect endangered species. The district court erred in substituting its judgment for that of the Agency.

Questions Presented

1. Whether the National Marine Fisheries Service acted arbitrarily and capriciously in imposing a seasonal closure of the LMA 1 Restricted Area to lobster fishing with vertical buoy lines based on statistical modeling and without more concrete data on whale presence.
2. Whether the district court abused its discretion in granting a preliminary injunction enjoining the seasonal closure.

Disposition

vacated