Relentless, Inc. v. U.S. Department of Commerce

Protecting American fishermen from out-of-control regulatory agencies

About the Case

Southeastern Legal Foundation (SLF) and the Defense of Freedom Institute filed an amicus brief supporting Relentless and Huntress, Inc., two small commercial fishing businesses, in their request that the Supreme Court to accept their case for review. This case involves a rule enacted by the National Marine Fisheries Service (NMFS). Under it, Herring fishermen like Relentless and Huntress to have federal monitors on their boats, and then pay for it, even though Congress never specifically authorized this action.

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NMFS proposed the rule in light of what it called “budget uncertainties” that would inhibit NMFS from paying for its own observers. Even though Congress never gave NMFS this power, the lower courts deferred to NMFS’s interpretation of the permissible scope of its own powers. Under the Magnuson-Stevens Act, Congress had only authorized NMFS to enact “necessary and appropriate regulations,” but that cannot mean NMFS has unlimited authority. The challenge was brought by the New Civil Liberties Alliance.

SLF urged the Supreme Court to accept this case. Allowing agencies to determine the scope of their own powers runs straight into separation of powers problems. And when Congress delegates the rulemaking function to agencies using cryptic and open-ended phrases, the problem is far more acute. The Supreme Court should use this case as an opportunity to place guardrails on agency overreach.

This is SLF’s most recent action taken to protect American fishermen from regulatory overreach on the part of National Marine Fisheries Service (NMFS). SLF recently filed comments challenging NMFS authority to set a speed limit and curfew on boaters in the Florida Gulf, a move criticized by SLF as “illegal and unconstitutional.”

Case Status

Amicus Brief

Court

U.S. Supreme Court

Why This Matters

Under important American principles of government, the functions of government are divided. From the outset, the Founders recognized that consolidated government would be a threat to the newly minted Nation, founded and conceived in individual liberty. Their elegant solution was to divide government.

But modern agencies perceive separation of powers to be an inefficient nuisance. Increasingly, they use the general grants of rulemaking given to it by Congress to simply fill in the details on laws that it has enacted as an excuse to expand their powers, wholesale, without limits. What NMFS has done here under its authority to enact “necessary and appropriate” rules is not new, but it is part of a persistent threat to our system of governance. When courts fail to enforce those limits, Americans cannot count on the lines of government being neatly divided as the Founders intended.

This case is about something far greater than small fish. To remain free, the courts must not think they should “defer” to an agency’s interpretation of its own power. Agencies must not treat general statutory authority as an excuse to accrue power that Congress has not and, in many cases, could not delegate to them.

The Supreme Court should take this opportunity to cure legal recognition of the principle that courts are to defer to an agency’s interpretation. Also, the Supreme Court should place parameters on the meaning of language surrounding the “necessary and appropriate” terminology so as to avoid interpreting those words in a manner that would create a constitutional problem.

Why This Matters

Under important American principles of government, the functions of government are divided. From the outset, the Founders recognized that consolidated government would be a threat to the newly minted Nation, founded and conceived in individual liberty. Their elegant solution was to divide government.

But modern agencies perceive separation of powers to be an inefficient nuisance. Increasingly, they use the general grants of rulemaking given to it by Congress to simply fill in the details on laws that it has enacted as an excuse to expand their powers, wholesale, without limits. What NMFS has done here under its authority to enact “necessary and appropriate” rules is not new, but it is part of a persistent threat to our system of governance. When courts fail to enforce those limits, Americans cannot count on the lines of government being neatly divided as the Founders intended.

This case is about something far greater than small fish. To remain free, the courts must not think they should “defer” to an agency’s interpretation of its own power. Agencies must not treat general statutory authority as an excuse to accrue power that Congress has not and, in many cases, could not delegate to them.

The Supreme Court should take this opportunity to cure legal recognition of the principle that courts are to defer to an agency’s interpretation. Also, the Supreme Court should place parameters on the meaning of language surrounding the “necessary and appropriate” terminology so as to avoid interpreting those words in a manner that would create a constitutional problem.

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