The America Tunaboat Association (ATA) brought an action to enjoin the National Marine Fisheries Service (NMFS) from enforcing the fishing ban NMFS determined was necessary to prevent ATA from killing more dolphins than its permit quota allowed. The Ninth Circuit held that the closure was reasonable in order to meet the dolphin quota for a particular year and that the quota must be lower than the quota for the prior calendar year. Because ATA had rapidly approached its prior year's quota, the court found the NMFS closure of the fishery cost ATA only a week's revenue and therefore the ATA's injury was insufficient to support a preliminary injunction.

The Marine Mammal Protection Act and the International Dolphin Conservation Act (IDCA) set a quota on the number of dolphins that ATA could kill during purse seining of tuna. Unless a global moratorium on the intentional taking of dolphins took place in March 1994, ATA would be limited to taking no more dolphins in 1994 than it took in 1993. In 1993, ATA took 115 dolphins and in early February 1994, ATA had already reported 107 dolphin mortalities. Because NMFS learned of the high rate of dolphin mortalities, and that no global moratorium would ensue by March 1994, it issued the fisheries closure to prevent ATA from exceeding its quota.

ATA argued that the closure was not timely because it had not yet reached its allowable quota on the day NMFS issued the closure notice. The Ninth Circuit found that ATA was not significantly harmed by NMFS's violation of the notice requirement because it was necessary for NMFS to take action to prevent ATA from violating the quota provision by the time the provision officially took place. The court found that NMFS's interpretation of the IDCA was permissible and that the violation of the notice requirement cost ATA only a week's worth of revenue. The Ninth Circuit agreed with the district court that the delay incurred by ATA in obtaining this relief did not rise to the level of irreparable injury required to support a preliminary injunction.