United States v. Hayes
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Introduction
Gun control has been hotly debated for years, with the first gun control act being passed in 1934 in an attempt to decrease crime. In 1968, the Gun Control Act was passed prohibiting most felons, drug users, and mentally incompetent people from purchasing guns. In 1996, Congress extended the Gun Control Act to also apply to those who have been previously convicted of a domestic violence–related misdemeanor. This extension has led to 17% fewer gun-related homicides of female partners, 31% fewer gun-related homicides of domestic, male children, and 24% fewer gun-related homicides of parents and siblings. The precise meaning and application of the added language was clarified a decade ago in the Supreme Court case United States v. Hayes.
Facts
Randy Hayes pled guilty to a misdemeanor for spousal abuse in West Virginia in 1994. In 2004, the police found a Winchester rifle while searching his home after receiving a domestic violence call. In West Virginia, it is illegal for someone previously convicted of a misdemeanor involving domestic violence against a partner to own a firearm, and Hayes was charged with this violation. Hayes responded that his 1994 misdemeanor didn’t qualify because he no longer lived with the spouse he lived with in 1994.
Legal Background
The U.S. District Court in the Northern District of West Virginia rejected Hayes’ argument. As a result, Hayes entered a “conditional guilty plea,” which allowed him to appeal his case to a higher court. The Fourth Circuit reversed the district court, holding that a conviction of a misdemeanor battery did not count as a crime of domestic violence. They reasoned that because the generic law didn’t classify what a domestic relationship was, Hayes’ offense lacked the element of a domestic relationship; therefore, the crime could not be considered a crime of domestic violence.
Holding & Reasoning
The Court held that the gun ban applies whenever the victim is a spouse or relative of the offender. The definition of “misdemeanor crime of domestic violence” contained two requirements. First, the crime must have the element of physical force or the threat of using a deadly weapon. Second, the offender who commits the crime must have a specified domestic relationship with the victim. The main topic in question was the element of the domestic relationship between the aggressor and the victim. The Court held that the domestic relationship, established beyond a reasonable doubt, doesn’t need to be a defining element of the established offense.
United States v. Hayes is based on 18 U.S.C. § 922(g)(9), which prohibits a person who has been convicted of a misdemeanor domestic violence crime from possessing firearms or ammunition. The Hayes Court also relied on United States v. Meade, in which the First Circuit specifically distinguished an offender’s relationship with the victim from the offender’s acts, calling them “conceptually distinct attributes.”
Analysis
Based on § 922(g)(9), the Supreme Court correctly decided the case. This holding was correct because § 922(g)(9) specifically states that the domestic relationship includes people the offender lives with or has a romantic relationship with. Even if a couple is legally separated or no longer live together when the offender is in possession of a firearm, at the time of the misdemeanor conviction, the fact that they were in a domestic relationship mandates that the domestic violence attribute shouldn’t be separated from the misdemeanor. Also, based on the holding of US v. Meade, both aspects of living with or having a romantic relationship with someone don’t need to be used because they are “conceptually distinct attributes.” This statute doesn’t allow someone who was previously convicted of a misdemeanor domestic crime to own a firearm.
United States v. Hayes also supports keeping firearms out of the hands of domestic abusers, who are usually not charged with or convicted of felonies, which would usually keep them from purchasing a firearm. By extending § 922(g)(9) and prohibiting someone who is convicted of a misdemeanor crime of domestic violence, it closes this loophole of owning a firearm while also being a domestic offender. United States v. Hayes ultimately ended the argument of needing a specific definition of “domestic relationship” in § 922(g)(9), thereby establishing a new precedent for cases involving domestic relationships and firearms.