United States v. Castleman

Background

James Castleman pleaded guilty in Tennessee to intentionally or knowingly causing bodily injury to the mother of his child. Years later he was charged in federal court with possessing firearms under a federal law that bars anyone convicted of "a misdemeanor crime of domestic violence." Lower courts held his Tennessee conviction did not qualify because they read the statute to require violent force.

Reasoning

The Court examined whether the statute’s phrase "use ... of physical force" means only violent force or includes the old common-law meaning of offensive touching. The majority adopted the common-law meaning, explaining that causing bodily injury necessarily involves physical force and that intentional or knowing application of force counts as a "use" of force. Using the categorical approach, the Court concluded Castleman’s plea showed the necessary element of force and reversed the Sixth Circuit.

Real world impact

The decision means many misdemeanor domestic-assault convictions that involve intentional or knowing bodily injury can disqualify people from possessing firearms under federal law. Federal prosecutors and defendants will focus on charging and plea documents to show whether a conviction involved the required element of force. The opinion resolves a split among federal appeals courts. The Court remanded the case for further proceedings consistent with this interpretation and did not resolve any constitutional challenges to the ban.

Dissents or concurrances

Justice Scalia concurred in the judgment but argued for a narrower rule requiring violent force; Justices Alito and Thomas joined a separate concurrence expressing different interpretive views.