Voisine v. United States, 136 S. Ct. 2272

Congress enacted 18 U.S.C. §922(g)(9) (and defined “misdemeanor crime of domestic violence” in §921(a)(33)(A)) in 1996 to prohibit firearm possession by persons convicted of misdemeanor domestic-assault offenses that have, as an element, the “use … of physical force.”
Petitioners Voisine and Armstrong had prior Maine misdemeanor assault convictions under a statute criminalizing conduct that "intentionally, knowingly or recklessly" causes bodily injury/offensive contact; both later possessed firearms and were charged under §922(g)(9).
The dispositive question: whether a misdemeanor conviction based on reckless (rather than knowing or intentional) conduct qualifies as a "misdemeanor crime of domestic violence" because it necessarily involves the "use ... of physical force."
The First Circuit upheld the convictions; the Supreme Court granted certiorari to resolve a circuit split about whether reckless domestic assaults trigger §922(g)(9).
The Supreme Court (majority) affirmed: it held that reckless domestic assaults fall within §921(a)(33)(A)’s "use ... of physical force" language; Justice Thomas (joined partially by Justice Sotomayor) dissented.

Issue	Plaintiff's Argument (Voisine/Armstrong)	Defendant's Argument (United States)	Held
Does a misdemeanor assault conviction based on recklessness qualify as a “misdemeanor crime of domestic violence” because it has as an element the “use … of physical force”?	Reckless conduct does not amount to the "use" of force; "use" requires intentional or knowing employment of force, so convictions allowing mere recklessness cannot trigger §922(g)(9).	"Use" means the volitional employment of force; reckless assaults involve conscious disregard of a substantial risk and thus are volitional, deliberate choices that constitute "use" of force.	Held: Reckless domestic assaults qualify; §921(a)(33)(A) encompasses reckless conduct.

United States v. Castleman, 572 U.S. 157 (2014) (interpreted "force" to include offensive touching and held knowing/intentional application of force is a "use")
Leocal v. Ashcroft, 543 U.S. 1 (2004) (held the "use" of force excludes merely accidental conduct)
United States v. Hayes, 555 U.S. 415 (2009) (held a conviction under a general assault statute can qualify as a predicate for §922(g)(9) if the requisite domestic relationship is shown)
Bailey v. United States, 516 U.S. 137 (1995) (construed "use" of a firearm as active employment)
Descamps v. United States, 570 U.S. 254 (2013) (explained when a state offense that "sweeps more broadly" than a federal definition cannot qualify as a predicate)