SCOTUSblog: United States v. Castleman
Argument: Jan 15 2014 (Aud.)
Background: In 2001, James Castleman pleaded guilty to one count of misdemeanor domestic assault in violation of Tennessee Code § 39-13-111(b) for "intentionally or knowingly cause bodily injury to [the mother of his child]." Several years later, federal agents discovered that Castleman and his wife were buying firearms from dealers and selling them on the black market. Under the Castlemans' scheme, Castleman's wife purchased firearms, allegedly lied on federal firearms paperwork by stating that she was the actual buyer of the firearms, and turned the firearms over to her husband, who was legally prohibited from purchasing firearms because of his domestic assault conviction. One of the firearms Castleman's wife allegedly purchased was recovered in a homicide investigation in Chicago, Illinois. An investigation by the Bureau of Alcohol, Tobacco, Firearms & Explosives (ATF) led agents to the Castlemans. A grand jury indicted Castleman on two counts of possession of a firearm after being "convicted...of a misdemeanor crime of domestic violence," in violation of 18 U.S.C. § 922(g)(9). The District Court dismissed the § 922(g)(9) counts in Castleman's indictment, reasoning that Castleman's misdemeanor domestic assault conviction did not qualify as a domestic violence crime because the statute required "force in the sense of violent contact" instead of merely "force as a scientific concept relating to the movement of matter." The Sixth Circuit affirmed.
Issue: The question before the Court is whether the 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” under 18 U.S.C. § 922(g)(9).
Holding: In a 9-0 decision, the Supreme Court ruled that Castleman's conviction qualifies as a "misdemeanor crime of domestic violence." Section 922(g)(9)’s “physical force” requirement is satisfied by the degree of force that supports a common-law battery conviction—namely, offensive touching.