United States v. Gonzalez

Defendant was convicted of three counts of unlawful exporting based on his sale of hundreds of AK-47 magazines out of his army surplus store. On appeal, defendant argued that the empty AK-47 magazines are not a prohibited item under the export laws. Defendant contended that empty AK-47 magazines do not qualify as firearm components because the Munitions List does not mention assault rifle magazines in the definition of “component.” The court concluded that an AK-47 magazine plainly meets the State Department’s definition of component. Further, the district court properly concluded that the Munitions List - which is a list of categories, not specific products - encompasses AK-47 magazines whether or not they are loaded with cartridges when shipped. Accordingly, the court affirmed the judgment. View "United States v. Gonzalez" on Justia Law