United States v. Castleman
572 U.S. ___ (2014)

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Justia Opinion Summary
Castleman was indicted under 18 U.S.C. 922(g)(9), for possession of a firearm by a person convicted of a “misdemeanor crime of domestic violence.” He argued that his Tennessee conviction for “intentionally or knowingly caus[ing] bodily injury to” the mother of his child did not qualify as a “misdemeanor crime of domestic violence” because it did not involve “use or attempted use of physical force.” The district court dismissed, reasoning that “physical force” must entail violent contact and that bodily injury can be caused without violent contact, e.g., by poisoning. The Sixth Circuit affirmed on different reasoning: that the degree of physical force required for a “misdemeanor crime of domestic violence” is the same as that required for a “violent felony” under the Armed Career Criminal Act, violent force, and that Castleman could have been convicted for causing slight injury by nonviolent conduct. The Supreme Court reversed, holding that section 922(g)(9)’s “physical force” requirement is satisfied by the “offensive touching” degree of force that supports a common-law battery conviction. Congress presumably intends to incorporate the common-law meaning of terms and nothing suggests a different intention here. While the word “violent” or “violence” standing alone “connotes a substantial degree of force,” “domestic violence,” is a term of art encompassing acts that one might not characterize as “violent” in a nondomestic context. There is no anomaly in grouping domestic abusers convicted of generic assault or battery offenses with others disqualified by section 922(g) from gun ownership. Application of the modified categorical approach—consulting the indictment to determine whether Castleman’s conviction entailed the elements necessary to constitute the generic federal offense—is straightforward. The “knowing or intentional causation of bodily injury” necessarily involved use of physical force. The common-law concept of “force” encompasses even its indirect application; the knowing or intentional application of force is a “use” of force.

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued.The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader.See United States v. Detroit Timber & Lumber Co., 200 U. S. 321 .

SUPREME COURT OF THE UNITED STATES

Syllabus

UNITED STATES v. CASTLEMAN

certiorari to the united states court of appeals for the sixth circuit

No. 12–1371. Argued January 15, 2014—Decided March 26, 2014

Respondent Castleman moved to dismiss his indictment under 18 U. S. C. §922(g)(9), which forbids the possession of firearms by anyone convicted of a “misdemeanor crime of domestic violence.” He argued that his previous conviction for “intentionally or knowingly caus[ing] bodily injury to” the mother of his child, App. 27, did not qualify as a “misdemeanor crime of domestic violence” because it did not involve “the use or attempted use of physical force,” 18 U. S. C. §921(a)(33)(A)(ii). The District Court agreed, reasoning that “physical force” must entail violent contact and that one can cause bodily injury without violent contact, e.g., by poisoning. The Sixth Circuit affirmed on a different rationale. It held that the degree of physical force required for a conviction to constitute a “misdemeanor crime of domestic violence” is the same as that required for a “violent felony” under the Armed Career Criminal Act (ACCA), §924(e)(2)(B)(i)—namely, violent force—and that Castleman could have been convicted for causing slight injury by nonviolent conduct.

Held: Castleman’s conviction qualifies as a “misdemeanor crime of domestic violence.” Pp. 4–16.

     (a) 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. Congress presumably intends to incorporate the common-law meaning of terms that it uses, and nothing suggests Congress intended otherwise here. The Sixth Circuit relied upon Johnson v. United States, 559 U. S. 133 , in which the common-law meaning of “force” was found to be a “comical misfit,” id., at 145, when read into ACCA’s “violent felony” definition. But Johnson resolves this case in the Government’s favor: The very reasons for rejecting the common-law meaning in Johnson are reasons to embrace it here. First, whereas it was “unlikely” that Congress meant to incorporate in ACCA’s “violent felony” definition “a phrase that the common law gave peculiar meaning only in its definition of a misdemeanor,” id., at 141, it is likely that Congress meant to incorporate the misdemeanor-specific meaning of “force” in defining a “misdemeanor crime of domestic violence.” Second, whereas the word “violent” or “violence” standing alone “connotes a substantial degree of force,” id., at 140, that is not true of “domestic violence,” which is a term of art encompassing acts that one might not characterize as “violent” in a nondomestic context. Third, whereas this Court has hesitated to apply ACCA to “crimes which, though dangerous, are not typically committed by those whom one normally labels ‘armed career criminals,’ ” Begay v. United States, 553 U. S. 137 , there is no anomaly in grouping domestic abusers convicted of generic assault or battery offenses together with others whom §922(g) disqualifies from gun ownership. In addition, a contrary reading would have made §922(g)(9) inoperative in at least ten States when it was enacted. Pp. 4–10.

     (b) Under this definition of “physical force,” Castleman’s conviction qualifies as a “misdemeanor crime of domestic violence.” The application of the modified categorical approach—consulting Castleman’s state indictment to determine whether his conviction entailed the elements necessary to constitute the generic federal offense—is straightforward. Castleman pleaded guilty to “intentionally or knowingly caus[ing] bodily injury to” the mother of his child, and the knowing or intentional causation of bodily injury necessarily involves the use of physical force. First, a “bodily injury” must result from “physical force.” The common-law concept of “force” encompasses even its indirect application, making it impossible to cause bodily injury without applying force in the common-law sense. Second, the knowing or intentional application of force is a “use” of force. Leocal v. Ashcroft, 543 U. S. 1 , distinguished. Pp. 10–13.

     (c) Castleman claims that legislative history, the rule of lenity, and the canon of constitutional avoidance weigh against this Court’s interpretation of §922(g)(9), but his arguments are unpersuasive. Pp. 14–15.

695 F. 3d 582, reversed and remanded.

     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 part and concurring in the judgment. Alito, J., filed an opinion concurring in the judgment, in which Thomas, J., joined.

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