## Facts

- Cayman Turtle Farm, Ltd. operated a mariculture facility on Grand Cayman that bred green sea turtles in captivity and exported turtle products (e.g., meat, oil, leather, jewelry) to the United States and other markets.
- The dispute concerned regulations issued in 1978 by the Secretaries of the Interior and Commerce implementing the Endangered Species Act of 1973 (ESA) and CITES.
- The regulations effectively prohibited importation into the United States of green sea turtle products, including products derived from captive-bred turtles produced by mariculture operations.
- The agencies treated farmed products the same as wild products, citing enforcement difficulties in distinguishing sources and concern that lawful trade could mask illegal trade and increase pressure on wild populations.
- The farm asserted that captive breeding aided conservation and argued for an exemption or more permissive treatment for captive-bred specimens.

## Issues

1. Whether the import restrictions on farmed green sea turtle products exceeded the Secretaries’ authority under the ESA.
2. Whether the regulations were contrary to CITES, including any provisions addressing captive-bred specimens.
3. Whether the regulations were arbitrary or capricious or unsupported by the administrative record under the Administrative Procedure Act (APA).

## Decision

- The court denied the farm’s motion for summary judgment and granted summary judgment to the federal defendants and intervenor-defendants.
- The court held the ESA authorized the agencies to regulate farmed green sea turtle products as strictly as wild products when necessary to protect the species.
- The court held the regulations were consistent with CITES because the Convention permits parties to adopt stricter domestic trade controls.
- The court held the agencies’ decision was supported by the administrative record and was not arbitrary or capricious under APA review.

## Legal Principles

- The ESA confers broad regulatory authority to implement prohibitions on import and trade to conserve listed species, including authority to adopt measures addressing enforcement feasibility and conservation risk.
- ESA protections focus on conserving the species, and agencies may regulate captive-bred specimens in the same manner as wild specimens where differential treatment would undermine enforcement or conservation objectives.
- CITES sets minimum international trade controls; it does not bar the United States from imposing more restrictive measures through domestic law.
- Under the APA’s arbitrary-and-capricious standard, courts defer to reasonable agency determinations grounded in the record, especially where agencies make science-based predictive judgments about conservation and enforcement.

## Conclusion

The court upheld the federal regulations banning importation of green sea turtle products, including those from captive-bred mariculture operations, concluding the measures were within ESA authority, compatible with CITES, and reasonable under deferential APA review.


Cayman Turtle Farm, Ltd. v. Andrus, 478 F. Supp. 125 (D.D.C. 1979)