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[JURIST] The US Supreme Court [official website] on Wednesday ruled in US v. Castleman [opinion, PDF; SCOTUSblog backgrounder] that a federal law [18 USC § 922(g)(9), text] banning gun possession after a state domestic abuse conviction involving “physical force” can be satisfied by the degree of force supporting a common law battery conviction, namely, “offensive touching.” In 2001, James Alvin Castleman pleaded guilty to a Tennessee misdemeanor of having “intentionally or knowingly cause[d] bodily injury to” the mother of his child. The federal government thereafter caught Castleman with a gun, and a grand jury indicted him under the federal gun possession law. Castleman moved to dismiss the indictment, arguing the federal law’s definition of “physical force” was narrower in scope than the state law’s definition of “bodily injury.” In reversing a US Court of Appeals for the Sixth Circuit [official website] decision, the Supreme Court found unanimously that Castleman’s state domestic abuse conviction fit within the federal law’s definition of a “misdemeanor crime of domestic violence.” The court reasoned that Castleman’s knowing or intentional causation of bodily injury necessarily involved the use of “physical force,” which Congress meant to encompass the “well-settled” meaning and scope of common-law battery.
The Supreme Court has issued decisions with respect to this specific federal gun possession law, the Armed Career Criminals Act (ACCA), in the past. In February 2009 court ruled [JURIST report] 7-2 in United States v. Hayes that the federal gun law does not require that a domestic relationship between an attacker and victim be a specific element of the crime in order for it to apply. In January 2009 the court ruled [JURIST report] in Chambers v. United States that failure to report to prison does not constitute a “violent felony” for purposes of sentence enhancement under the federal gun law.
