United States v. Hayes
Citations
- 555 U.S. 415
- 129 S. Ct. 1079
- 172 L. Ed. 2d 816
- 2009 U.S. LEXIS 1634
About this case
From Wikipedia, the free encyclopedia
2009 United States Supreme Court case
United States v. Hayes, 555 U.S. 415 (2009), is a United States Supreme Court case interpreting Section 921(a)(33)(A) of the federal Gun Control Act of 1968, as amended in 1996. The Court held that a domestic relationship is not necessarily a defining element of the predicate offense to support a conviction for possession of a firearm by a person previously convicted of a misdemeanor crime of domestic violence.
Background
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The Gun Control Act had long prohibited convicted felons from owning firearms . In 1996 the Act was amended[1] to extend this prohibition to persons convicted of a "misdemeanor crime of domestic violence ."
The question before the Court was the statutory meaning of this prohibition, and how far it extended: did it require a state to have a specific statute that prohibited misdemeanor crimes of domestic violence, under which a person charged with an Act violation was convicted? Or did it only require that a person was convicted of a misdemeanor which in fact constituted "domestic violence," without regard to whether the misdemeanor statute specifically proscribed crimes of "domestic violence"?
Facts and Issues
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The facts of the Hayes case illustrate the distinction. In 1994 Hayes had been convicted in West Virginia of the misdemeanor of simple battery . The offense was committed against his wife in a domestic dispute. In 2004, the police found him in possession of firearms. Had he violated the Act?
The prosecution claimed the 1994 conviction for simple battery was sufficient to place him under the federal firearms ban. He had been convicted of a violent misdemeanor (battery) under state law. And the battery was, in fact, against his wife. This was enough, the prosecution alleged, to make that a conviction of a predicate crime of "domestic violence" which would, accordingly, bring him within the scope of the federal prohibition.
Hayes claimed that more was required before he was subject to the federal firearms possession ban of the Gun Control Act. He argued that the state must have a statute that specifically defined and prohibited "domestic violence" as an independent crime; a person convicted of that crime would then be subject to the federal prohibition under Act, but a person only convicted of another crime - such as simple battery - would not be so subjected.
Hayes agreed the person he battered was, in fact, his wife; but in 1994 the state of West Virginia did not have a statute that prohibited "domestic violence" as a specific crime. Therefore, Hayes argued, it was in effect legally impossible for him to be banned from firearm possession under the "domestic violence" extension for acts committed within West Virginia.
Hayes moved to dismiss the federal indictment but the trial court denied his motion. He entered a guilty plea, subject to his right to appeal the motion's denial, and the Fourth Circuit Court of Appeals agreed with Hayes on appeal. It decided that the state misdemeanor law must contain, as an element of the crime, a "domestic relationship between the offender and the victim," 482 F.3d 749, 751 (2007), and that the indictment was indeed faulty. The Supreme Court then accepted the case to resolve a split among the circuits.
Supreme Court decision
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The Supreme Court agreed with the Government that the indictment was sufficient and that the Fourth Circuit's interpretation of the Gun Control amendments was erroneous.
References
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- ↑ Section 922(g), defining the categories of persons to whom the ban extended, was expanded to add a new category under Section 922(g)(9), which included "a person convicted of a misdemeanor crime of domestic violence" within the firearms possession prohibition. In addition, a definition of "crime of domestic violence" was added as a new Section 933(a)(33)(A).
External links
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- Text of United States v. Hayes, 555 U.S. 415 (2009) is available from: CourtListener Findlaw Internet Archive (docket files) Justia Oyez (oral argument audio) Supreme Court (slip opinion) (archived)
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How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that a statute with the phrase \offense ... committed by a current or former spouse\ allowed for case-specific consideration
- holding that § 922(g)(9) applies whenever predicate offense was committed within specified type of domestic relationship
- holding that although the government must prove the existence of the qualifying relationship under section 922(g)(9), such a relationship is not a required statutory element
- stating that the rule of lenity applies when a statute is still ambiguous after applying the other canons of statutory construction
- acknowledging that the statute at issue was “not a model of the careful drafter’s art,” but rejecting the applicability of the rule of lenity because the statute was not grievously ambiguous
- noting that conceptually distinct attributes of a crime, e.g. the action taken by the defendant and his or her relationship to the victim, cannot constitute one element
Source: CourtListener parenthetical corpus (CC0).
Judges: Ginsburg, Stevens, Kennedy, Souter, Breyer, Alito, Thomas, Roberts, Scalia
Read full opinion on CourtListenerCited by
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Cites
26 cases in this archive are cited by this case; the 20 most cited are listed.
- Taylor v. United StatesSupreme Court· 1990-05-29· cited 5,461×
- Shepard v. United StatesSupreme Court· 2005-03-07· cited 4,574×
- Exxon Mobil Corp. v. Allapattah Services, Inc.Supreme Court· 2005-06-23· cited 2,717×
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court· 1980-06-09· cited 2,564×
- Rowland v. California Men's Colony, Unit II Men's Advisory CouncilSupreme Court· 1993-01-12· cited 2,320×
- Barnhart v. ThomasSupreme Court· 2003-11-12· cited 1,983×
- Bragdon v. AbbottSupreme Court· 1998-06-26· cited 1,379×
- Bifulco v. United StatesSupreme Court· 1980-06-16· cited 734×
- Crandon v. United StatesSupreme Court· 1990-02-27· cited 696×
- United States v. ShabaniSupreme Court· 1994-11-01· cited 687×
- Merrill Lynch, Pierce, Fenner & Smith Inc. v. DabitSupreme Court· 2006-03-21· cited 550×
- Board of Governors of the Federal Reserve System v. Dimension Financial Corp.Supreme Court· 1986-01-22· cited 444×
- Huddleston v. United StatesSupreme Court· 1974-03-26· cited 422×
- Castillo v. United StatesSupreme Court· 2000-06-05· cited 359×
- First National Bank in St. Louis v. MissouriSupreme Court· 1924-01-28· cited 263×
- United States v. William Maurice SmithEighth Circuit· 1999-03-24· cited 182×
- United States v. MeadeFirst Circuit· 1999-05-12· cited 166×
- United States v. ChavezEleventh Circuit· 2000-02-29· cited 122×
- United States v. Barnes, JohnD.C. Circuit· 2002-07-23· cited 89×
- United States v. SheltonFifth Circuit· 2003-03-18· cited 75×
Other cases named United States v. Hayes
128 other CourtListener records share this case name; the 50 most cited are listed.
- United States v. HayesEleventh Circuit· 1984-01-13· cited 62×
- United States v. HayesEighth Circuit· 2008-03-14· cited 59×
- United States v. HayesCourt of Appeals for the Armed Forces· 2012-02-13· cited 44×
- United States v. HayesUnited States Court of Military Appeals· 1958-01-31· cited 39×
- United States v. HayesSecond Circuit· 2008-12-24· cited 34×
- United States v. HayesNinth Circuit· 1949-02-14· cited 30×
- United States v. HayesEighth Circuit· 2009-08-03· cited 28×
- United States v. HayesFifth Circuit· 2003-08-06· cited 25×
- United States v. HayesFifth Circuit· 1994-09-01· cited 24×
- United States v. HayesN.D. Iowa· 2013-06-07· cited 19×
- United States v. HayesEighth Circuit· 1927-05-28· cited 17×
- United States v. HayesUnited States Court of Military Appeals· 1957-01-04· cited 17×
- United States v. HayesEighth Circuit· 2008-07-31· cited 15×
- United States v. HayesFifth Circuit· 2008-06-20· cited 13×
- United States v. HayesW.D. Kentucky· 1966-03-21· cited 11×
- United States v. HayesM.D. North Carolina· 1986-04-25· cited 10×
- United States v. HayesUnited States Court of Military Appeals· 1980-10-06· cited 8×
- United States v. HayesCourt of Appeals for the Armed Forces· 2012-05-01· cited 7×
- United States v. HayesD. Puerto Rico· 1979-06-14· cited 7×
- United States v. HayesU.S. Army Court of Military Review· 1987-06-29· cited 6×
- United States v. HayesUnited States Court of Military Appeals· 1993-03-25· cited 6×
- United States v. HayesS.D. New York· 2015-08-03· cited 5×
- United States v. HayesSeventh Circuit· 2017-10-03· cited 5×
- United States v. HayesU S Coast Guard Court of Military Review· 1994-08-25· cited 5×
- United States v. HayesN.D. Alabama· 1989-01-11· cited 4×
- United States v. HayesS.D. New York· 2015-03-20· cited 4×
- United States v. HayesU.S. Army Court of Military Review· 1976-06-30· cited 4×
- United States v. HayesU.S. Army Court of Military Review· 1993-06-21· cited 4×
- United States v. HayesFirst Circuit· 2005-08-09· cited 3×
- United States v. HayesE.D. Michigan· 2005-05-27· cited 3×
- United States v. HayesE.D. New York· 1931-10-15· cited 3×
- United States v. HayesNinth Circuit· 2008-06-27· cited 3×
- United States v. HayesS.D. Texas· 1965-11-08· cited 3×
- United States v. HayesW.D. Pennsylvania· 1975-01-28· cited 3×
- United States v. HayesN.D. Indiana· 1986-10-20· cited 2×
- United States v. HayesW.D. New York· 2008-07-23· cited 2×
- United States v. HayesDistrict of Columbia Court of Appeals· 1970-12-16· cited 2×
- United States v. HayesN.D. West Virginia· 2005-06-24· cited 2×
- United States v. HayesUnited States Court of Military Appeals· 1969-11-14· cited 2×
- United States v. HayesU.S. Army Court of Military Review· 1977-05-06· cited 2×
- United States v. HayesS.D. Iowa· 2002-06-05· cited 1×
- United States v. HayesDistrict of Columbia· 2017-06-09· cited 1×
- United States v. HayesSecond Circuit· 1954-05-17· cited 1×
- United States v. HayesSixth Circuit· 2001-05-09· cited 1×
- United States v. HayesNinth Circuit· 2003-03-21· cited 1×
- United States v. HayesSixth Circuit· 2003-04-01· cited 1×
- United States v. HayesW.D. Virginia· 2019-01-04· cited 1×
- United States v. HayesSeventh Circuit· 2009-12-21· cited 1×
- United States v. HayesU.S. Navy-Marine Corps Court of Military Review· 1980-07-10· cited 1×
- United States v. HayesUnited States Court of Military Appeals· 1981-07-13· cited 1×
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