Skip to main content
Federal & State Lawfederalstatelaw.com
Home/Federal/Cases
Supreme Court· 2/24/2009

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

Jump to content

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

[(https://en.wikipedia.org/w/index.php?title=United_States_v._Hayes&action=edit&section=1 "Edit section: Background")
]

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

[(https://en.wikipedia.org/w/index.php?title=United_States_v._Hayes&action=edit&section=2 "Edit section: Facts and Issues")
]

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

[(https://en.wikipedia.org/w/index.php?title=United_States_v._Hayes&action=edit&section=3 "Edit section: Supreme Court decision")
]

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

[(https://en.wikipedia.org/w/index.php?title=United_States_v._Hayes&action=edit&section=4 "Edit section: References")
]

  1. ↑ 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

[(https://en.wikipedia.org/w/index.php?title=United_States_v._Hayes&action=edit&section=5 "Edit section: External links")
]

Retrieved from "https://en.wikipedia.org/w/index.php?title=United_States_v._Hayes&oldid=1351936147 "

Categories :

Hidden categories:

Search

Search

United States v. Hayes

Add languages Add topic

Editorial context from Wikipedia (CC-BY-SA 4.0).

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 CourtListener

Cited by

192 cases in this archive cite this case; the 20 most cited are listed.

Cites

26 cases in this archive are cited by this case; the 20 most cited are listed.

Other cases named United States v. Hayes

128 other CourtListener records share this case name; the 50 most cited are listed.

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.