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United States v. James Alvin Castleman

Summarized by: 

Date Filed: March 26, 2014
Case #: 12–1371
Sotomayor, J. delivered the opinion of the Court, in which Roberts, C.J., and Kennedy, Ginsburg, Breyer, and Kagan, JJ., joined. Scalia, J., filed an opinion concurring in the judgment. Alito, J., filed an opinion concurring in the judgement, in which Thomas, J., joined.
Full Text Opinion: http://www.supremecourt.gov/opinions/13pdf/12-1371_6b35.pdf

Criminal Law: A conviction for misdemeanor domestic assault by intentionally or knowingly causing bodily injury to a parent of his/her child qualifies as a conviction for a "misdemeanor crime of domestic violence."

Respondent was indicted for violating  18 U.S.C. § 922(g)(9), which forbids possession of firearms by anyone convicted of a “misdemeanor crime of domestic violence.” Respondent was previously convicted of “intentionally or knowingly causing bodily injury” to the mother of his child in violation of Tenn. Code Ann. § 39-13-111(b)(Supp. 2002).

The District Court held that the Respondent’s Tennessee conviction did not qualify as a “misdemeanor crime of domestic violence” because he did not use physical force. The Sixth Circuit Court of Appeals affirmed the District Court’s decision, holding that Respondent’s conviction did not qualify as a “misdemeanor crime of domestic violence,” because the conviction could encompass crimes not characterized by the use of physical force.

The Supreme Court reversed and remanded, holding that following their decision in Johnson v United States, 559 U. S. 133 (2010), the Respondent’s conviction qualifies as a “misdemeanor crime of domestic violence,” under 18 U.S.C. § 922(g)(9) because the Respondent's indictment states a use of physical force,  which meets the element of the required physical force to support a common-law battery conviction.