Jack's Canoes & Kayaks, LLC v. National Park Service, 933 F. Supp. 2d 58

Plaintiff Jack’s Canoes & Kayaks, LLC operates a boathouse business on two Georgetown Waterfront parcels, Lot 805 (leased from the District) and Lot 806 (owned by Plaintiff).
Historical transfer process began with the 1985 DC Council Resolution initiating transfer of administrative jurisdiction over Lot 805 to the NPS for Georgetown Waterfront Park, with conditions including lease assignments and revenue use for park development.
The District later executed an Assignment Agreement in 2000 assigning leases on Georgetown Waterfront Park to the National Park Foundation (NPF) rather than directly to the NPS, with NPS directing NPF to accept the assignment and to act as its agent for lease obligations.
Plaintiff acquired the Lease and Lot 805 in 2007 (Plaintiff’s predecessor transferred rights in 2007; Baxter family involvement historically preceded Plaintiff).
NPF regularly cashed Plaintiff’s rent checks until August 2012; thereafter NPF stopped cashing rent through January 2013 while Plaintiff faced potential termination of occupancy.
In December 2012, NPS gave notice to terminate occupancy by January 31, 2013; in January 2013, NPS indicated termination would occur upon execution of a concessions contract, and issued an RFQ for concession operators, with Plaintiff not submitting a response.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge transfer of jurisdiction	Plaintiff seeks declarations invalidating the transfer to NPS and reversion to DC.	District contends Plaintiff lacks constitutional standing and claims are time-barred.	Plaintiff lacks standing for the transfer-declaration claim against the District.
Standing to challenge assignment of Lease to NPF	Plaintiff challenges whether the Lease was properly assigned to NPF under the 1985 Resolution and subsequent legislation.	District/Park Defendants contend assignment was authorized and effective; Plaintiff’s standing is disputed elsewhere.	Plaintiff has standing to challenge the assignment to NPF, but the claim is barred by the statute of limitations.
Likelihood of success on the merits for injunction against Park Defendants	Park Defendants lack authority to terminate the Lease or eject Plaintiff without a court order.	NPS/NFP actions to terminate are within concessions policy and proper notice was given; Plaintiff’s actions are speculative.	Plaintiff fails to show likelihood of success on the merits; injunction denied.
Irreparable harm and public interest	Immediate termination would destroy Plaintiff’s business; irreparable harm is imminent.	No irreparable harm; potential relocation or continuation via concession; delay undermines policy goals.	Irreparable harm and public-interest factors weigh against a preliminary injunction.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (establishes the constitutional standing framework (injury, causation, redressability))
Friends of the Earth v. Laidlaw Environmental Services, 528 U.S. 167 (2000) (standing and redressability considerations in declaratory context)
U.S. Ecology, Inc. v. U.S. Dept. of Interior, 231 F.3d 20 (D.C. Cir. 2000) (standing and redressability in agency-action challenges)
Texas Alliance for Home Care Services v. Sebelius, 811 F. Supp. 2d 76 (D.D.C. 2011) (standing and ripeness considerations in regulatory challenges)
Connors v. Hallmark & Son Coal Co., 935 F.2d 336 (D.C. Cir. 1991) (discovery rule and accrual of claims for statute of limitations)
NB ex rel. Peacock v. District of Columbia, 682 F.3d 77 (D.C. Cir. 2012) (procedural injury and standing considerations in public-right challenges)
Winter v. NRDC, 555 U.S. 7 (2008) (preliminary injunction standards and irreparable harm framework)
Mideast Systems & China Civil Const. Saipan Joint Venture, Inc. v. Hodel, 792 F.2d 1172 (D.C. Cir. 1986) (causation and redressability concepts in standing analysis)
Moms Against Mercury v. FDA, 483 F.3d 824 (D.C. Cir. 2007) (standing and jurisdictional considerations in agency challenges)
Acme Process Equipment Co. v. United States, 347 F.2d 509 (Ct. Cl. 1965) (contractual waiver principles in standing/relief analysis)