United States v. Hayes

PETITIONER: United States
RESPONDENT: Randy Edward Hayes
LOCATION: Home of Randy Edward Hayes

DOCKET NO.: 07-608
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 555 US (2009)
GRANTED: Mar 24, 2008
ARGUED: Nov 10, 2008
DECIDED: Feb 24, 2009

ADVOCATES:
Nicole A. Saharsky - Assistant to the Solicitor General, Department of Justice, argued the cause for the petitioner
Troy N. Giatras - argued the cause for the respondent

Facts of the case

Under West Virginia law, it is unlawful for any person who has been convicted of a misdemeanor crime of domestic violence to possess a firearm. In 1994, Randy Hayes pled guilty in West Virginia to a misdemeanor battery offense after striking his wife. Ten years later, in 2004, police responded to a domestic violence call at Hayes' home. While conducting a search of the premises the police uncovered a Winchester rifle. They arrested Hayes for possessing a firearm after being convicted of a misdemeanor crime of domestic violence based on the 1994 plea. Hayes argued that his prior conviction for misdemeanor battery did not constitute a conviction for a misdemeanor crime of violence under the statute. The U.S. District Court for the Northern District of West Virginia rejected this argument and Hayes entered a conditional guilty plea to reserve his claim for appeal.

Hayes' strategy was a success, as the U.S. Court of Appeals for the Fourth Circuit reversed the district court. The court held that conviction of a misdemeanor battery does not qualify as a crime of domestic violence, noting that the legislative intent and plain meaning of the statute indicated that the original offense must involve a "domestic" relationship between the victim and offender. Finding this requirement unfulfilled in the case, the Fourth Circuit reversed Hayes' conviction.

Question

Under the Gun Control Act of 1968, does a conviction for misdemeanor battery constitute a "misdemeanor crime of domestic violence" when the victim was the offender's wife and the predicate offense statute did not designate a "domestic relationship" between aggressor and victim as an element of the crime?

Media for United States v. Hayes

Audio Transcription for Oral Argument - November 10, 2008 in United States v. Hayes

Audio Transcription for Opinion Announcement - February 24, 2009 in United States v. Hayes

John G. Roberts, Jr.:

Justice Ginsburg has our opinion this morning in case 07-608, United States versus Hayes.

Ruth Bader Ginsburg:

Federal law has long prohibited the possession of firearms by a convicted felon.

In 1996, Congress extended this ban to persons convicted of a misdemeanor crime of domestic violence.

The definition of that phrase is the issue in this case.

Does it cover a misdemeanor battery whenever the battered victim was in fact the offender's current or former spouse or other statutorily defined domestic relation notably the offender's child?

Or is the gun possession ban triggered only when the predicate misdemeanor identifies as an expressed element of the crime, a domestic relationship between the aggressor and the victim.

We hold that the domestic relationship while that must be established beyond a reasonable doubt need not be a defining element of the predicate events.

Respondent Randy Hayes was charged with three counts of possessing firearms after having been convicted of a misdemeanor crime of domestic violence.

The indictment identified Hayes' predicate events as a 1994 conviction for battery in violation of West Virginia law.

The victim of that battery was Hayes' then wife.

Hayes sought to dismiss the indictment observing that his West Virginia statute of conviction was a generic battery proscription.

The firearm ban he asserted applied only to persons convicted of an offense that includes a domestic relationship between the offender and the victim as a defining element.

The District Court rejected Hayes' argument, and Hayes entered a conditional guilty plea.

On appeal, the United States Court of Appeals for the Fourth Circuit agreed with Hayes and reversed.

In so holding, the Court split from the nine other Courts of Appeals that have decided the question.

We reverse the Fourth Circuit's judgment.

We first explain why the text and context of the governing statute support our reading.

We next take account of practical considerations.

Felon-in-possession laws, Congress recognized, were failing to keep firearms out of the hands of domestic abusers who are often charged with misdemeanors rather than felonies.

To close this loophole, Congress extended the federal firearm prohibition to misdemeanor crimes of domestic violence.

Excluding from the statutory definition, domestic abusers convicted under generic battery laws would frustrate Congress' manifest purpose.

As of 1996, only about a third of the states had criminal statutes that specifically proscribe domestic violence.

Even today, the number is only modestly higher.

If the Fourth Circuit were right in its analysis of the controlling legislation, Congress' enactment would have been a dead letter in the majorly of states from the very moment of its passage.

We decline to treat the congressional endeavor as in large measure ineffectual.

What little there is of legislative history corroborates our ruling, it indicates that Congress sought to apply the firearm ban to all persons convicted of domestic violence offenses whether or not the statutes of conviction happened to contain a domestic relations element.

Justice Thomas joins all but Part III of the Court's opinion.

The Chief Justice has filed a dissenting opinion in which Justice Scalia joins.