United States v. Castleman (2013)
- Docket
- 12-1371
- Decided
- 2013-01-01
Summary
Question: Does Castleman's conviction of misdemeanor domestic assault under Tennessee law constitute a misdemeanor crime of domestic violence under the relevant federal statute? Conclusion: Yes. Justice Sonia Sotomayor delivered the opinion for the 9-0 majority. The Court held that, because the statute in question—that prevents people convicted of misdemeanor domestic violence from possessing firearms—incorporates an element regarding the use of physical force, it includes those convicted of domestic assault under state law. This reading of the statute is consistent with the common-law meaning of violence, and to read it otherwise would have meant that the statute was ineffective in many states at the time of its enactment. Because the Tennessee statute under which Castleman was convicted necessarily involved the use of physical force, it should be considered a misdemeanor domestic violence conviction for the purpose of the federal statute. In his opinion concurring in part and concurring in the judgment, Justice Antonin Scalia wrote that the majority opinion could have settled the case on much narrower grounds than it did. Because the meaning of the Tennessee statute in question categorically includes the meaning of "physical force," a conviction under that statute qualifies as a misdemeanor crime of domestic violence. Justice Samuel A. Alito, Jr. wrote a separate opinion concurring in the judgment in which he argued that the reasoning in the majority opinion purports to rely on the reasoning in Johnson v. United States , but because the majority opinion in this case holds that force does not need to be violent, it is an improper application of the precedent. Justice Clarence Thomas joined in the opinion concurring in the judgment.