United States v. Hayes (2008)
- Docket
- 07-608
- Decided
- 2008-01-01
Summary
Question: Under the Gun Control Act of 1968, does a conviction for misdemeanor battery constitute a "misdemeanor crime of domestic violence" when the victim was the offender's wife and the predicate offense statute did not designate a "domestic relationship" between aggressor and victim as an element of the crime? Conclusion: Yes. The Supreme Court reversed the Fourth Circuit holding that the predicate offense statute need not include the existence of a "domestic relationship" as an element of the crime in order to qualify as a "misdemeanor crime of domestic violence" as specified by the Gun Control Act of 1968. With Justice Ruth Bader Ginsburg writing for the majority and joined by Justice John Paul Stevens, Justice Anthony M. Kennedy, Justice David H. Souter, Justice Stephen G. Breyer, and Justice Samuel A. Alito, and joined in part by Justice Clarence Thomas, the Court reasoned that the language of the Gun Control Act suggested that the predicate offense statute need only include "the use of force" as an element of the crime and need not include a "domestic relationship" as an additional element. Chief Justice John G. Roberts dissented and was joined by Justice Antonin G. Scalia. He criticized the majority opinion's use of grammatical rules by which it reached an unsound conclusion. He argued that the rule of lenity should apply as the Gun Control Act was ambiguous and therefore should be interpreted in the defendant's favor.