United States v. Castleman
United States Supreme Court
134 S. Ct. 1405 (2014)
- Written by Sara Rhee, JD
Facts
In 2001, James Alvin Castleman (defendant) was convicted of having “intentionally or knowingly cause[d] bodily injury” to the mother of his child in violation of a Tennessee statute. Seven years later, Castleman was charged with violating 18 U.S.C. § 922(g)(9) by possessing a firearm after having been convicted of a misdemeanor crime of domestic violence. Castleman moved to dismiss on the ground that the Tennessee statute under which he was convicted in 2001 did not require the use of physical force and therefore could not serve as a predicate offense under § 922(g)(9). The District Court for the Western District of Tennessee granted the motion, finding that physical force required violent contact. Because, under the Tennessee statute, Castleman could have caused bodily injury without using violent contact, the district court determined that the statute could not serve as a predicate offense under § 922(g)(9). The United States Court of Appeals for the Sixth Circuit affirmed. Certiorari was granted.
Rule of Law
Issue
Holding and Reasoning (Sotomayor, J.)
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