Voisine v. United States

136 S.Ct. 2272 (2016)

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Nature of the Case

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Facts

Congress enacted §922(g)(9) to “close [a] dangerous loophole” in the gun control laws. Many perpetrators of domestic violence are charged with misdemeanors rather than felonies, notwithstanding the harmfulness of their conduct. Congress prohibited any person convicted of a “misdemeanor crime of domestic violence” from possessing any gun or ammunition with a connection to interstate commerce. D pleaded guilty to assaulting his girlfriend in violation of §207 of the Maine Criminal Code, which makes it a misdemeanor to “intentionally, knowingly or recklessly cause[ ] bodily injury or offensive physical contact to another person.” Law enforcement officers learned that D owned a rifle. When a background check turned up his prior misdemeanor conviction, the Government charged him with violating 18 U. S. C. §922(g)(9). Armstrong (D1) pleaded guilty in 2008 to assaulting his wife in violation of a Maine domestic violence law making it a misdemeanor to commit an assault prohibited by §207 (the general statute under which D was convicted) against a family or household member. Law enforcement officers searched D1’s home as part of a narcotics investigation discovered six guns, plus a large quantity of ammunition. D1 was charged under §922(g)(9) for unlawfully possessing firearms. Ds argued that their prior convictions could have been based on reckless, rather than knowing or intentional, conduct. The District Court rejected those claims. D both pleaded guilty. The Court of Appeals affirmed the two convictions, holding that “an offense with a mens rea of recklessness may qualify as a ‘misdemeanor crime of violence’ under §922(g)(9).” The Supreme Court granted certiorari.