In the United States v. Randy Edward Hayes case of 2008, the Supreme Court ruled that a federal law banning gun possession by individuals convicted of misdemeanor domestic violence also applies to those who have pleaded guilty to common-law battery against their spouses or live-in partners. The ruling came after defendant Randy Edward Hayes was found in possession of firearms despite having been previously convicted for assaulting his then-wife, which is considered a misdemeanor crime under West Virginia law. He argued that this conviction should not trigger the federal ban as it did not specifically mention domestic relationship between him and his victim at the time he pled guilty. However, Justice John Paul Stevens writing for majority rejected this argument stating that Congress intended to bar all people convicted of violent acts against their family members from owning guns regardless if state laws label such offenses as 'domestic' or not.

In the dissenting opinion for United States v. Randy Edward Hayes, Justice Roberts disagreed with the majority's interpretation of federal law that prohibits individuals convicted of misdemeanor crimes of domestic violence from possessing firearms. He argued that this prohibition should only apply to those who have a legally defined relationship with their victim at the time of their conviction, not just at the time when they committed their crime. In his view, this would exclude people like Hayes who were not married to or cohabitating with their victims when they were convicted but may have been in such a relationship when they committed their offense. He also criticized the majority for relying on legislative history rather than clear statutory text and expressed concern about potential due process violations if individuals are punished based on relationships that weren't legally recognized at the time of conviction.