New England Fishermen's Stewardship Association v. Lutnick: New England Fishermen’s Stewardship Association v. Lutnick
The First Circuit held that the New England Fishery Management Council's role in developing Framework Adjustment 65 was purely advisory and did not violate the Appointments Clause. Consequently, the court affirmed the denial of injunctive relief and reversed the district court's severance of unrelated statutory provisions.