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Justice News

Department of Justice
U.S. Attorney’s Office
Western District of Tennessee

Wednesday, March 26, 2014

Unanimous Supreme Court Rules For The United States In Criminal Firearms Case From West Tennessee

Memphis, TN – Today, the United States Supreme Court handed the United States a unanimous victory in United States v. Castleman, a federal criminal case originating in the Western District of Tennessee, announced U.S. Attorney Edward L. Stanton III.

U.S. Attorney Stanton said, “We are extremely pleased with the Court’s decision. Castleman clarifies the law nationally and restores an important tool in the government’s toolbox. In particular, this decision means that federal prosecutors can continue to seek justice against – and protect victims from – those domestic abusers who arm themselves with firearms, not just in Tennessee but across the nation.”

Procedural history

In 2001, James Castleman was convicted of misdemeanor domestic assault in state court in Carroll County, Tennessee. The state indictment alleged that Castleman intentionally or knowingly caused bodily injury to the mother of his child.

In 2008, law enforcement agents discovered that Castleman and his wife were buying firearms from dealers and selling them on the black market. In August 2009, a federal grand jury in Memphis charged Castleman with two counts of possessing a firearm after having been convicted of a “misdemeanor crime of domestic violence,” in violation of 18 U.S.C. § 922(g)(9).

The district court granted the defendant’s motion to dismiss these federal charges in April 2010, on the basis that defendant’s prior Tennessee domestic assault conviction was not a “misdemeanor crime of domestic violence,” as that term is defined in federal law.

The United States appealed, and in September 2012 the U.S. Court of Appeals for the Sixth Circuit affirmed the district court’s ruling, with each Judge of the divided three-member panel writing separately. The government sought rehearing by the en banc Court of Appeals, but the court declined to reconsider its decision.

In May 2013, the United States filed a petition for a writ of certiorari from the Supreme Court. The Court granted that petition on October 1, 2013. The question presented before the Supreme Court was whether Castleman’s Tennessee conviction for misdemeanor domestic assault by intentionally or knowingly causing bodily injury to the mother of his child qualifies as a “misdemeanor crime of domestic violence” under federal law.

The Court’s decision

All nine Justices agreed that a Tennessee conviction for intentionally causing bodily injury to a family member constitutes a “misdemeanor crime of domestic violence” that triggers the firearms prohibition in § 922(g)(9). Thus, all Justices agreed that the Sixth Circuit’s opinion holding otherwise should be reversed.

In the lead opinion, written by Justice Sotomayor and joined by Chief Justice Roberts and Justices Kennedy, Ginsburg, Breyer, and Kagan, the Court held that the firearms prohibition for those convicted of a “misdemeanor crime of domestic violence” applies to those previously convicted of intentional domestic assault in Tennessee, as well as those convicted nationwide of similar statutes involving “the degree of force that supports a common-law battery conviction.” In part, this is because “‘[d]omestic violence’ is not merely a type of ‘violence’; it is a term of art encompassing acts that one might not characterize as ‘violent’ in a nondomestic context.”

The Court also noted that domestic abuse escalates in severity over time and that many perpetrators of domestic violence are convicted only of misdemeanors, not felonies.

Justice Scalia wrote an opinion concurring in part and concurring in the judgment. Justices Alito and Thomas concurred in the judgment.

The Court remanded Castleman’s case for further proceedings. The government’s prosecution of Castleman in the Western District of Tennessee can now proceed.

Assistant U.S. Attorney Daniel French and Criminal Appellate Chief Kevin G. Ritz represented the United States during the proceedings in the lower courts, and they, along with U.S. Attorney Stanton, attended the oral argument at the Supreme Court in January. The Office of the Solicitor General represented the government in the Supreme Court. Assistant to the Solicitor General Melissa Arbus Sherry argued the case for the United States.

Updated March 19, 2015