Supreme Court of the United States · 2009-02-24
18usc922: author: Fable · QA: PASS (QA2, neov2/qa/wave2-cases-QA2.md)
Case and law context
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; claim: (g)(9)
Uncertainty
None recorded
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.
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.
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 CA4's contrary ruling could be a superseded block but would only mirror this one; not recorded.
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.
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 12
| Case | One applicable prohibited category | Section 925(a)(1) government-use firearm or ammunition exception | Actual or constructive possession | Firearm or ammunition under section 921 | Possession in or affecting commerce | Knowledge of possessing the firearm or ammunition |
|---|---|---|---|---|---|---|
| United States v. Hayes — 555 U.S. 415 (2009) · Supreme Court of the United States · 2009 (18usc922: author: Fable · QA: PASS (QA2, neov2/qa/wave2-cases-QA2.md)) | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: applied/merits | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 12
| Case | Knowledge of the relevant disqualifying status | Second Amendment limit on the unlawful-user theory applied to Hemani | Ship or transport in interstate or foreign commerce | Knowing shipping, transportation or receipt | Receipt of the prohibited object | Received object previously shipped or transported across borders |
|---|---|---|---|---|---|---|
| United States v. Hayes — 555 U.S. 415 (2009) · Supreme Court of the United States · 2009 (18usc922: author: Fable · QA: PASS (QA2, neov2/qa/wave2-cases-QA2.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| United States v. Hayes — 555 U.S. 415 (2009) · Supreme Court of the United States · 2009 — not reached (18usc922: author: Fable · QA: PASS (QA2, neov2/qa/wave2-cases-QA2.md)) | Actual or constructive possession | not_reached Excluded from merits counts applied / merits claim: (g)(9) 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. | Unspecified route | No source quotation recorded for this block. |
| United States v. Hayes — 555 U.S. 415 (2009) · Supreme Court of the United States · 2009 — satisfied · pleaded (18usc922: author: Fable · QA: PASS (QA2, neov2/qa/wave2-cases-QA2.md)) | Misdemeanor crime of domestic violence | satisfied Counted merits instance applied / merits basis: pleaded; claim: (g)(9) 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). | predicate-offense-definition/generic-battery-conviction-with-domestic-victim-in-fact | The indictment identified Hayes’s predicate misdemeanor crime of domestic violence as a 1994 conviction for battery in violation of West Virginia law.Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [1542:1692] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.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.”Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [1693:1872] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.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.Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [2208:2427] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.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.Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [4995:5215] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.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.Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [12793:13155] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.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.Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [4838:4994] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.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.Source: docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [19171:19360] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5. |
Court interpretations recorded from this case
interpretation
We hold that the domestic relationship, although it must be established beyond a reasonable doubt in a § 922(g)(9) firearms possession prosecution, need not be a defining element of the predicate offense.
United States v. Hayes — 555 U.S. 415 (2009) · Supreme Court of the United States · 2009 (18usc922: author: Fable · QA: PASS (QA2, neov2/qa/wave2-cases-QA2.md))
We hold that the domestic relationship, although it must be established beyond a reasonable doubt in a § 922(g)(9) firearms possession prosecution, need not be a defining element of the predicate offense.Source:
docroot/ir/caselaw/us_555.jsonl#/us/555/0415-01; Unicode character offsets [758:962] (end exclusive); SHA-256 3a7a3039ef9688b8d4c2536bed0b3955aac1c4369fca644134b99ecce9c9e3a5.