The Fifth Circuit has denied a petition for review filed by a Haitian lawful permanent resident convicted of smuggling fifty firearms to Haiti concealed in vehicles, rejecting his argument that the security-related removability ground for violating export laws should be read narrowly to require an actual national security or public safety threat.
The Court held that the plain text of 8 U.S.C. § 1227(a)(4)(A)(i), covering any activity violating a law prohibiting the export of goods, is satisfied by the petitioner's federal conviction for unlicensed firearms exportation regardless of whether the specific shipment endangered national security, rejecting his noscitur a sociis argument as subordinate to the statute's plain text. A dissenting judge argued the majority's reading would extend to trivial regulatory violations like exporting a bag of chips and urged that the provision be read, in context, to require an actual public-safety or national-security nexus.
The full text of Olibris v. Blanche can be found here: https://www.ca5.uscourts.gov/opinions/pub/25/25-60322-CV0.pdf