Firearms — misdemeanor crime of domestic violence

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U.S. Supreme Court

Criminal

Firearms — misdemeanor crime of domestic violence

A state court battery conviction is a misdemeanor crime of domestic violence under 18 U.S.C. 922(g)(9).

Under this definition of “physical force,” Castleman’s conviction qualifies as a “misdemeanor crime of domestic violence.” The application of the modified categorical approach—consulting Castleman’s state indictment to determine whether his conviction entailed the elements necessary to constitute the generic federal offense—is straightforward. Castleman pleaded guilty to “intentionally or knowingly caus[ing] bodily injury to” the mother of his child, and the knowing or intentional causation of bodily injury necessarily involves the use of physical force. First, a “bodily injury” must result from “physical force.” The common-law concept of “force” encompasses even its indirect application, making it impossible to cause bodily injury without applying force in the common-law sense. Second, the knowing or intentional application of force is a “use” of force. Leocal v. Ashcroft, 543 U. S. 1, distinguished.

695 F. 3d 582, reversed and remanded.

12-1371 U.S. v. Castleman

Sotomayor, J.; Scalia, J., concurring; Alito, J., concurring.