United States v. Hayes

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  • Violence Against Women and Girls
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2009

Determined whether the federal domestic violence misdemeanor gun ban law—the Lauternberg Amendment—requires a domestic relationship between the offender and the victim.

Background of the Case

At issue in United States v. Hayes was whether the Lautenberg Amendment, which prohibits gun ownership by persons convicted of a "misdemeanor crime of domestic violence," applies only to individuals who violate laws that specifically prohibit violence against family members, or if it also applies to anyone convicted of a violent misdemeanor that was, in fact, committed against a family member.  

In 1994, Randy Hayes plead guilty to a misdemeanor battery against his then-wife and mother of his child; ten years later, police responded to a call regarding domestic violence at his home, where they found a rifle and arrested and indicted him for violating the Lautenberg Amendment.  Hayes requested the federal district court to dismiss his indictment on the grounds that his prior conviction was not “a misdemeanor crime of domestic violence,” in that the law that he violated did not require a domestic relationship between the victim and the offender. The district court denied his motion to dismiss the indictment, and Hayes appealed to the U.S. Court of Appeals for the Fourth Circuit.

In their 2007 decision on United States v. Hayes, the Fourth Circuit agreed with Hayes’ argument, and ruled that the domestic relationship must indeed be a specific element of the prior offense in order to trigger the federal gun ban—effectively rendering the gun ban moot in the states that do not have misdemeanor laws specific to domestic violence.

Decision

Reversing the Fourth Circuit’s ruling, the Supreme Court’s decision holds that the gun ban applies whenever the battered victim is in fact the spouse or other family relative of the offender. In the majority opinion, Supreme Court Justice Ruth Bader Ginsburg wrote, "It suffices for the government to charge and prove a prior conviction that was, in fact, an offense committed… against a spouse or other domestic victim."