United States v. Castleman
134 S. Ct. 1405
| SCOTUS | 2014Background
- James Castleman pleaded guilty (Tenn. Code Ann. §39‑13‑111(b)) to intentionally or knowingly causing bodily injury to the mother of his child (a misdemeanor domestic-assault conviction).
- Years later he was indicted under 18 U.S.C. §922(g)(9), which prohibits firearm possession by anyone convicted of a “misdemeanor crime of domestic violence.”
- §921(a)(33)(A)(ii) defines that term as an offense that “has, as an element, the use or attempted use of physical force” (or threatened use of a deadly weapon) by a qualifying relationship.
- Castleman argued his Tennessee conviction did not require the “use of physical force” because bodily injury can be caused indirectly (e.g., poisoning) without violent contact.
- The District Court agreed; the Sixth Circuit affirmed on a different ground, applying Johnson’s “violent force” standard and concluding Castleman could have been convicted for nonviolent conduct.
- The Supreme Court granted certiorari to resolve a circuit split about the meaning of “physical force” in §921(a)(33)(A)(ii).
Issues
| Issue | Plaintiff's Argument (United States) | Defendant's Argument (Castleman) | Held |
|---|---|---|---|
| Meaning of “physical force” in §921(a)(33)(A)(ii) | Congress intended the common‑law meaning of force (the degree supporting a battery: offensive touching); common‑law meaning fits this misdemeanor‑specific definition | “Physical force” should require violent force (as in Johnson) or at least force capable of serious injury | The Court held “physical force” is satisfied by the degree of force that supports a common‑law battery (offensive touching) |
| Whether Castleman’s Tennessee conviction qualifies | The indictment charging intentional/knowing causation of bodily injury necessarily involves use of physical force and thus meets §922(g)(9) | Conviction could rest on non‑contact or non‑forceful means (e.g., poisoning); Leocal’s “use” requirement limits coverage | The Court held knowing/intentionally causing bodily injury necessarily involves applying physical force and is a “use” of force, so the conviction qualifies |
| Nontextual challenges (legislative history, lenity, constitutional avoidance) | Text, structure, purpose, and common law control; Jay legislative history and purpose support a broad reading to close gun‑access loophole | Legislative debate focused on severe domestic violence; rule of lenity and Second Amendment concerns counsel narrower reading | The Court rejected these arguments: legislative history and canons do not create grievous ambiguity warranting lenity or avoidance; statute unambiguous under the Court’s interpretation |
Key Cases Cited
- Johnson v. United States, 559 U.S. 133 (interpreting “physical force” in ACCA and holding it means violent force)
- Leocal v. Ashcroft, 543 U.S. 1 (holding “use” requires more than negligent conduct; discussed as controlling meaning of “use”)
- Taylor v. United States, 495 U.S. 575 (categorical approach for comparing convictions to generic federal offenses)
- Shepard v. United States, 544 U.S. 13 (permitting limited documents in modified categorical approach)
- Begay v. United States, 553 U.S. 137 (caution about extending ACCA to atypical offenses)
- United States v. Hayes, 555 U.S. 415 (context on why Congress enacted §922(g)(9) to close a domestic‑violence loophole)