Source: cases/18usc922/us-555-415-us-v-hayes.case
Case source: https://www.neochart.com/catalog/cases/us/volume_555/0415_01/index.html
Instead, in a § 922(g)(9) prosecution, it suffices for the Government to charge and prove a prior conviction that was, in fact, for “an offense . . . committed by” the defendant against a spouse or other domestic victim.
To obtain a conviction in a § 922(g)(9) prosecution, the Government must prove beyond a reasonable doubt that the victim of the predicate offense was the defendant’s current or former spouse or was related to the defendant in another specified way. But that relationship, while it must be established, need not be denominated an element of the predicate offense.
In line with the large majority of the Courts of Appeals, we conclude that § 921(a)(33)(A) does not require a predicate-offense statute of that specificity.
For the reasons stated, the judgment of the United States Court of Appeals for the Fourth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.
casedsl 1 case /us/555/0415-01 name United States v. Hayes cite 555 U.S. 415 (2009) court Supreme Court of the United States date 2009-02-24 url catalog/cases/us/volume_555/0415_01/index.html source ir/caselaw/us_555.jsonl sha1=5238ddc88834f28a7dbb5ee12ca4544a033c132f chars=38332 law 18usc922 (g)(9) role applied posture criminal; motion to dismiss the indictment denied, conditional guilty plea; CA4 reversed (predicate offense must have a domestic-relationship element); certiorari by the United States on the meaning of "misdemeanor crime of domestic violence" in 921(a)(33)(A) result claimant-won element status.g9 : satisfied [pleaded] variant predicate-offense-definition/generic-battery-conviction-with-domestic-victim-in-fact fact @1542..1692 [supports] | The indictment identified Hayes’s predicate misdemeanor crime of domestic violence as a 1994 conviction for battery in violation of West Virginia law. fact @1693..1872 [supports] | The victim of that battery, the indictment alleged, was Hayes’s then-wife — a person who “shared a child in common” with Hayes and “who was cohabitating with ... him as a spouse.” fact @2208..2427 [cuts-against] | The West Virginia statute under which he was convicted in 1994, Hayes observed, was a generic battery proscription, not a law designating a domestic relationship between offender and victim as an element of the offense. rule @4995..5215 | Instead, in a § 922(g)(9) prosecution, it suffices for the Government to charge and prove a prior conviction that was, in fact, for “an offense . . . committed by” the defendant against a spouse or other domestic victim. rule @12793..13155 | To obtain a conviction in a § 922(g)(9) prosecution, the Government must prove beyond a reasonable doubt that the victim of the predicate offense was the defendant’s current or former spouse or was related to the defendant in another specified way. But that relationship, while it must be established, need not be denominated an element of the predicate offense. held @4838..4994 | In line with the large majority of the Courts of Appeals, we conclude that § 921(a)(33)(A) does not require a predicate-offense statute of that specificity. held @19171..19360 | For the reasons stated, the judgment of the United States Court of Appeals for the Fourth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion. gloss The indictment was sufficient as charged: a generic battery conviction qualifies when the victim was in fact a spouse or other listed relation. Only the use-of-force requirement must be an element of the predicate statute; the domestic relationship is a fact the Government must prove beyond a reasonable doubt in the 922(g)(9) prosecution itself. Whether the relationship was actually proved was not before the Court (conditional plea on the indictment's allegations). element possession : not-reached gloss Officers found a rifle in Hayes's home on a consent search and learned of other recent firearms; three possession counts; not contested in this opinion. misfit The ruling is a construction of the 921(a)(33)(A) definition that splits status.g9 into two differently-proved parts (force = element of the predicate statute, categorical; domestic relationship = fact proved in the federal prosecution). The law file declares no sub-ids for these prongs, so "which prong must be an offense element" lives only in the variant label, rule lines and gloss. misfit Basis is single-valued: the decision is a pure question of law (would be [law]) applied to an indictment taken as true on a motion to dismiss (recorded [pleaded]), followed by a conditional guilty plea that the reversal leaves standing. Result "claimant-won" reflects that the conviction on the plea survives, although the Court formally reversed and remanded. misfit Known: the rejected reading (CA4's "relationship must be an element of the predicate") is a negative ruling about a proposed requirement; no way to say "X is not required" except in gloss. CA4's contrary ruling could be a superseded block but would only mirror this one; not recorded. misfit Roberts, C.J. (joined by Scalia, J.) dissented on text and lenity; not read beyond its opening and not recorded as a scope dissent block.