Term: 2013
Docket: 12-1371
United States v. Castleman
- Pro
12-1371 UNITED STATES V. CASTLEMAN DECISION BELOW: 695 F.3d 582 CERT. GRANTED 10/1/2013 QUESTION PRESENTED: Section 922(g)(9) of Title 18, United States Code, makes it a crime for any person convicted of a "misdemeanor crime of domestic violence" to possess a firearm. The phrase "misdemeanor crime of domestic violence" is defined to include any federal, state, or tribal misdemeanor offense, committed by a person with a specified domestic relationship to the victim, that "has, as an element, the use or attempted use of physical force, or the threatened use of a deadly weapon." 18 U.S.C. 921(a)(33)(A). The question presented is: Whether respondent's Tennessee conviction for misdemeanor domestic assault by intentionally or knowingly causing bodily injury to the mother of his child qualifies as a conviction for a "misdemeanor crime of domestic violence." LOWER COURT CASE NUMBER: 10-5912
The United States v. Castleman case in 2013 revolved around the interpretation of a federal law that prohibits individuals convicted of "misdemeanor crimes of domestic violence" from owning firearms. The defendant, James Alvin Castleman, was charged with illegal possession of a firearm following his previous conviction for misdemeanor domestic assault in Tennessee. He argued that his conviction did not qualify as a "crime of domestic violence" under federal law because it involved only minor physical contact and thus didn't meet the requirement for "physical force." However, the Supreme Court disagreed and upheld his indictment by ruling unanimously that even minor acts like offensive touching can be considered violent force under this context. Therefore, such convictions do trigger the gun ownership ban imposed by federal law on those guilty of misdemeanors involving domestic violence.
In the dissenting opinion for United States v. Castleman, Justice Scalia disagreed with the majority's interpretation of "physical force" in relation to misdemeanor crimes of domestic violence under federal law. He argued that the majority’s broad definition was inconsistent with common-law understanding and could potentially criminalize minor acts such as a squeeze on the arm causing a bruise or a slap in the face. According to him, this would lead to an overreach by federal law into what should be state-level offenses. Furthermore, he criticized how this ruling might affect Second Amendment rights because it could prohibit individuals convicted of these misdemeanors from owning firearms under another federal statute.
