The case of Voisine v. United States (2015) revolved around the interpretation of a federal law that prohibits individuals convicted of misdemeanor domestic violence from possessing firearms. The petitioners, Stephen Voisine and William Armstrong III, both from Maine, had prior convictions for misdemeanor assault under state law and were later found with firearms and charged under federal law. They argued their initial crimes did not qualify as "misdemeanor crimes of domestic violence" because they involved reckless conduct rather than intentional or knowing harm to another person - a requirement they believed was necessary according to the language in the statute. However, in a 6-2 decision led by Justice Elena Kagan, the Supreme Court ruled against them stating that even minor acts committed recklessly can trigger criminal liability under this particular gun control provision.

In the dissenting opinion for Voisine v. United States, Justice Clarence Thomas, joined by Justice Sonia Sotomayor in part, argued that the majority's interpretation of federal law was too broad and could potentially infringe on an individual's Second Amendment rights. He disagreed with the majority’s view that a reckless domestic assault qualifies as a "misdemeanor crime of domestic violence," which would prohibit individuals convicted under this category from possessing firearms under 18 U.S.C §922(g)(9). Thomas contended that such an expansive reading of “use...of physical force” to include recklessness goes beyond Congress’ intent when they enacted this statute. Furthermore, he expressed concerns about how broadly interpreting these laws might impact gun ownership rights protected by the Second Amendment.