Bond v. United States, 134 S. Ct. 2077

Bond, a Pennsylvania microbiologist, committed sting-like acts by spreading toxic chemicals on Haynes’s property in a personal feud; she did not intend to kill and Haynes suffered only a minor burn.
Bond was charged in federal court with mail theft and possessing/using a chemical weapon under 18 U.S.C. §229(a).
Section 229 defines a “chemical weapon” and “toxic chemical” with broad terms, potentially covering local offenses.
Bond argued the statute exceeds Congress’s powers under the Tenth Amendment; the Third Circuit initially held for Bond on standing, later rejecting the challenge.
The issue this case turns on is whether §229 reaches Bond’s local conduct or whether treaty-implementing limits restore state authority over such offenses.
The Court ultimately reversed the Third Circuit, holding §229 does not reach Bond’s local assault and that implementing the Chemical Weapons Convention does not authorize federal prosecution of purely local crimes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §229(a)(1) reaches Bond’s local assault	Bond argues statute intrudes on state police power	United States contends broad §229 reach is necessary to implement the treaty	No; §229 does not reach Bond’s local conduct.
Whether applying §229 to Bond is a valid exercise of treaty power	Bond asserts treaty does not authorize domestic criminalization of a local crime	Government argues treaty implementation justifies broader federal reach	Not necessary to decide treaty scope; read §229 narrowly under federalism.
Whether the statute's term “chemical weapon” has an ordinary meaning that would expand federal reach	Bond contends ordinary meaning limits reach	Government argues broad statutory definition governs	Court favors ordinary meaning limiting to non-war context; avoids federal overreach.
Whether Congress could have used the treaty power to justify §229	Treaty power cannot justify broad domestic police power	Treaty power may justify implementing legislation	Treaty power cannot expand federal reach without clear constitutional authority.

United States v. Bass, 404 U. S. 336 (1971) (presume federal statutes do not abrogate state sovereignty unless clearly stated)
Jones v. United States, 529 U. S. 848 (2000) (most sensible reading to avoid broad federal domain in criminal law)
Missouri v. Holland, 252 U. S. 416 (1920) (treaty power does not equal unlimited federal authority; context matters)