First Circuit Affirms Lobster Pot Decision

The Providence Journal reports that a final lid was put on the number of lobster pots allowed lobstermen in Rhode Island when the First Circuit Court of Appeals upheld a decision by District Court Chief Judge Mary Lisi.

The case was initially brought by certain lobstermen as a state-court challenge to regulations promulgated by the Rhode Island Department of Environmental Management which imposed restrictions on lobster-trap allocations for Rhode Island waters.

The opinion, penned by Judge Bruce Selya, concludes there there is federal jurisdiction over the litigation and then quickly resolves the merits of the case:

The plaintiffs’ asseverational array involves claims that the contested regulation violates the Rhode Island Constitution and a myriad of state statutory provisions. See R.I. Gen. Laws §§ 20-2.1-9, 20-7-9, 42-35-3, 42-35-3.3. This onslaught boils down to two principal assertions. First, the plaintiffs posit that the challenged regulation abridges their fundamental right of equal access to the fisheries, and denies them equal protection, R.I. Const. art. I, §§ 2, 17. Second, they maintain that the Commission did not really mandate the use of retroactive control dates when Addendum VII was adopted and, thus, the challenged regulation offends R.I. Gen. Laws § 20-2.1-9. The district court patiently explained why neither of these assertions holds water. See RIFA II, 2008 WL 4467186, at *5-11 (rejecting arguments based on state constitution); id. at *12-14 (rejecting plaintiffs’ suggested interpretation of Addendum VII). The court also convincingly dispatched the plaintiffs’ arguments arising out of other Rhode Island statutes. See, e.g., id. at *11-12, *14-16.

We often have said, and today reaffirm, that when a trial court addresses issues squarely and in detail, writes a persuasive opinion that faithfully applies the law to the facts, and reaches a correct result, there is no need for a reviewing court to write at length merely to hear its own words resonate. See, e.g., Vargas-Ruiz v. Golden Arch Dev., Inc., 368 F.3d 1, 2 (1st Cir. 2004) (collecting cases); Henry v. Connolly, 910 F.2d 1000, 1002 (1st Cir. 1990). This is precisely such an instance.

Here, the district court wrote a thoughtful and comprehensive rescript explaining its multi-faceted rationale for rebuffing the plaintiffs’ challenge to the contested regulation and granted summary judgment accordingly. We largely agree with the reasoning set forth in the lower court’s rescript, and uphold its merits ruling for substantially the reasons set forth in that opinion.


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