State of Washington v. United States Department of State

CourtDistrict Court, W.D. Washington
DecidedMarch 6, 2020
Docket2:20-cv-00111
StatusUnknown

This text of State of Washington v. United States Department of State (State of Washington v. United States Department of State) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Washington v. United States Department of State, (W.D. Wash. 2020).

Opinion

HONORABLE RICHARD A. JONES 1

14 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 15 AT SEATTLE

16 STATE OF WASHINGTON; et al., 17 Plaintiffs, Case No. 2:20-cv-00111-RAJ 18 v. ORDER GRANTING IN PART 19 PLAINTIFF STATES’ MOTION UNITED STATES DEPARTMENT OF FOR PRELIMINARY 20 STATE; et al, INJUNCTION

21 Defendants. 22 I. INTRODUCTION 23 This matter comes before the Court on the Plaintiff States’ Motion for Preliminary 24 Injunction (“Motion”). Dkt. # 55. For the reasons below, the Court GRANTS IN PART 25 the Motion. 26 27 1 II. BACKGROUND 2 Plaintiffs are seventeen States challenging companion regulations promulgated by 3 the Department of State and the Department of Commerce. This action is the latest in a 4 series of litigation over export controls on technical data related to 3-D printed firearms. 5 The Court examines the statutory framework and prior litigation before turning to its 6 analysis. 7 A. Arms Export Control Act (“AECA”) 8 The AECA regulates the export of arms, ammunition, and other military and 9 defense technology. 22 U.S.C. § 2778(a)(1). It delegates to the President the task of 10 creating the United States Munitions List (“Munitions List”), which designates certain 11 items as defense articles and defense services. Id. The term “defense articles” specifically 12 includes “technical data recorded or stored in any physical form, models, mockups or 13 other items that reveal technical data directly relating to items designated in” the 14 Munitions List. 22 C.F.R. § 120.6. Category I of the Munitions List includes “Firearms, 15 Close Assault Weapons and Combat Shotguns.” 22 C.F.R. § 121.1. “Nonautomatic and 16 semi-automatic firearms to caliber .50 inclusive,” their “components, parts, accessories 17 and attachments,” and related “technical data” are currently within Category I. Id. § 18 121.1(a), (h), (i). 19 The AECA also tasks the President with promulgating regulations for the import 20 and export of such defense articles and services. 22 U.S.C. § 2778(a)(1). The President 21 has delegated his authority to promulgate implementing regulations to the Secretary of 22 State. Those regulations, the International Traffic in Arms Regulations (“ITAR”), are 23 administered by the DDTC [Directorate of Defense Trade Controls] and its employees. 22 24 C.F.R. § 120.1(a). Under ITAR, persons who want to export items on the Munitions List 25 must first obtain a license from the Department of State (“State Department”). 26 B. Export Control Reform Act 27 The Department of Commerce (“Commerce”) regulates exports pursuant to the 1 Export Control Reform Act of 2018, 50 U.S.C. §§ 4801-52 (“ECRA”), which directs that 2 export controls be used to “further significantly the foreign policy of the United States,” to 3 “fulfill [the] declared international obligations” of the United States, or to limit exports 4 that would make a “significant contribution to the military potential of any other country 5 or . . . would prove detrimental to . . . national security.” Id. § 4811(1)(A)-(B). 6 To carry out these purposes, the ECRA directs that Commerce shall “establish and 7 maintain a list of items that are controlled”—the Commerce Control List (“CCL”)—and 8 “prohibit unauthorized exports, reexports, and in-country transfers of controlled items.” 50 9 U.S.C. § 4813(a)(1), (3). The Export Administration Regulations (“EAR”), 15 C.F.R. 10 parts 730-774, implement the ECRA, identifying the items and activities subject to the 11 jurisdiction of the EAR as well as those not subject to the EAR. The EAR’s definition of 12 “export” is comprehensive, and extends to, inter alia, “(1) An actual shipment or 13 transmission out of the United States, including the sending or taking of an item out of the 14 United States, in any manner;” or “(2) Releasing or otherwise transferring ‘technology’ or 15 source code (but not object code) to a foreign person in the United States (a ‘deemed 16 export’).” 15 C.F.R. § 734.13(a). 17 C. Prior Litigation 18 Computer software for the production of a Category I firearm or its components 19 using a 3-D printer (“3-D gun files”), such as computer aided design (CAD) files, is 20 “technical data” subject to the AECA and ITAR. Since about 2013, it had been the 21 government’s position that posting 3-D gun files on the internet was an “export” subject to 22 the AECA and ITAR. Defense Distributed, a private company with the stated objective of 23 facilitating global, unrestricted access to firearms and evading gun-safety laws, challenged 24 the government’s authority in a lawsuit filed in the United States District Court for the 25 Western District of Texas. Distributed v. U.S. Dep’t of State, C15-0372RP (W.D. Tex). 26 The company alleged that the government’s prepublication approval requirements under 27 ITAR were unconstitutionally applied to its gun-related speech. Id. Defense Distributed 1 sought an injunction so that it could post its 3-D gun files on the internet without 2 restriction to allow people to easily produce their own weapons and weapon parts using 3 relatively affordable and readily available equipment. 4 Throughout the litigation, the government argued that the export of certain Defense 5 Distributed 3-D gun files could “cause serious harm to U.S. national security and foreign 6 policy interests” that “warrant subjecting [the files] to ITAR’s export licensing regime.” 7 Dkt. # 32 at 19-20 (W.D. Tex.). The government specifically expressed that the 3-D gun 8 files could be modified to create lethal firearms that were “virtually undetectable” by 9 conventional security measures such as metal detectors. Additionally, the government 10 contended that permitting unrestricted access to the 3-D gun files on the internet would 11 increase the risk of their use in assassinations, in manufacturing spare component parts by 12 embargoed nations, terrorist groups, or guerrilla groups, or in compromising aviation 13 security overseas in a manner specifically directed at U.S. persons or interests. Id. The 14 government also argued that “the available alternatives clearly would be ineffective at 15 preventing the broad circumvention of export controls for munitions technology.” Dkt. # 16 92 at 27 (W.D. Tex.). The district court ultimately denied Defense Distributed’s motion 17 for preliminary injunction and the Fifth Circuit affirmed. Defense Distributed v. U.S. 18 Dep’t of State, 838 F.3d 451, 458 (5th Cir. 2016). The Fifth Circuit highlighted the State 19 Department’s very strong public interest in national defense and national security, noting 20 that the unregulated export of the 3-D gun files could cause permanent harm. Id. at 458. 21 In April 2018, Defense Distributed and the federal government reached a tentative 22 agreement to settle the dispute. Dkt. # 57 at 75-83. Pursuant to the settlement, the State 23 Department reversed its prior regulatory and litigation positions on publishing 3-D gun 24 files.

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