18 U.S.C. § 117

Domestic assault by an habitual offender

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(a)In General.—Any person who commits a domestic assault within the special maritime and territorial jurisdiction of the United States or Indian country and who has a final conviction on at least 2 separate prior occasions in Federal, State, or Indian tribal court proceedings for offenses that would be, if subject to Federal jurisdiction—(1) any assault, sexual abuse, or serious violent felony against a spouse or intimate partner, or against a child of or in the care of the person committing the domestic assault; or(2) an offense under chapter 110A,shall be fined under this title, imprisoned for a term of not more than 5 years, or both, except that if substantial bodily injury results from violation under this section, the offender shall be imprisoned for a term of not more than 10 years.(b)Domestic Assault Defined.—In this section, the term “domestic assault” means an assault committed by a current or former spouse, parent, child, or guardian of the victim, by a person with whom the victim shares a child in common, by a person who is cohabitating with or has cohabitated with the victim as a spouse, parent, child, or guardian, or by a person similarly situated to a spouse, parent, child, or guardian of the victim.(Added Pub. L. 109–162, title IX, § 909, Jan. 5, 2006, 119 Stat. 3084; amended Pub. L. 113–104, § 3, May 20, 2014, 128 Stat. 1156.)Editorial NotesAmendments

2014—Subsec. (a)(1). Pub. L. 113–104 inserted “, or against a child of or in the care of the person committing the domestic assault” after “intimate partner”.

Notes of Decisions
Cited in 37 cases (5 in the last 5 years), 2009–2024 · leading case: United States v. Bryant, 195 L. Ed. 2d 317 (2016).
United States v. Bryant, 195 L. Ed. 2d 317 (2016). · cites it 7× “18 U. S. C. §117 (a). Section 117(a)(1) provides that any person who “commits a domestic assault within .”
United States v. Lynn Michael LaVictor, 848 F.3d 428 (6th Cir. 2017). · cites it 4× “§ 113 (a)(6) (“Count Four”); and, (4) domestic assault by a habitual offender pursuant to 18 U.S.C. § 117 (“Count Five”). LaVictor was arrested on July 30, and arraigned a few days later by a magistrate judge who ordered that he have no contact with C.”
United States v. Terry Harlan, 815 F.3d 1100 (8th Cir. 2016). · cites it 5× “A jury found Terry Lee Harlan, a Native American man, guilty of domestic assault in Indian country by an habitual offender in violation of 18 U.S.C. § 117 . The district court 1 sentenced Harlan to 41 months imprisonment.”
United States v. Denny Johnson, Sr., 860 F.3d 1133 (8th Cir. 2017). · cites it 4× “§§ 1153 ,113(a)(5); and one count of domestic assault by a habitual offender, 18 U.S.C. § 117 . 3 The presen- *1139 tence report determined that Johnson’s base offense level under the Sentencing Guidelines was 30.”
United States v. Cavanaugh, 680 F. Supp. 2d 1062 (D.N.D. 2009). · cites it 20× “Unlike the Interstate Commerce Clause, which generally im *1065 pacts state regulation, the Indian Commerce Clause permits Congress to broadly regulate in the field of Indian affairs, and Congress was within its power to enact 18 U.S.C. § 117 as it applies to Indian country;…”
United States v. Shavanaux, 647 F.3d 993 (10th Cir. 2011). · cites it 6× “We consider the government’s appeal from the dismissal of Adam Shavanaux’s indictment under 18 U.S.C. § 117 (a) for domestic assault by a habitual offender.”
United States v. Michael Bryant, Jr., 769 F.3d 671 (9th Cir. 2014). · cites it 9× “BRYANT SUMMARY* Criminal Law The panel reversed the district court’s denial of a motion to dismiss an indictment charging the defendant, an Indian, with two counts of domestic assault by a habitual offender, in violation of 18 U.S.C. § 117 (a). Applying United States v.”
Samuel Silk, Jr. v. United States, 955 F.3d 681 (8th Cir. 2020). · cites it 5× “, appeals the district court’s judgment denying his motion to vacate his sentence imposed under 18 U.S.C. § 117 for the crime of domestic assault by a habitual offender in Indian country.”
United States v. Cavanaugh, 643 F.3d 592 (8th Cir. 2011). · cites it 2× “, was charged for the offense of domestic assault by a habitual offender, 18 U.S.C. § 117 . As elements of the offense, the government must prove Cavanaugh received "a final conviction on at least 2 separate prior occasions in Federal, State, or Indian tribal court proceedings"…”
United States v. Servando Alvarado-Casas, 715 F.3d 945 (5th Cir. 2013). “§ 115 (b)(1)(B)(iii)—(iv); 18 U.S.C. § 117 (a)(2); 18 U.S.C. § 241 ; 18 U.”
United States v. Kerby St. John, 716 F.3d 491 (8th Cir. 2013). · cites it 3× “John was charged with domestic assault by a habitual offender in violation of 18 U.S.C. § 117 . At trial St. John moved for a judgment of acquittal based on insufficient evidence, which the district court 1 denied.”
United States v. Santana Drapeau, 827 F.3d 773 (8th Cir. 2016). · cites it 4× “Santana Drapeau was convicted of one count of assault and two counts of domestic assault by a habitual offender, in violation of 18 U.S.C. § 117 . He argues that the district court 2 improperly admitted testimony by his then girlfriend, Dondee St.”
— 18 U.S.C. § 117(b) — 1 case
United States v. Lynn Michael LaVictor, 848 F.3d 428 (6th Cir. 2017). “§ 113 (a)(6) (“Count Four”); and, (4) domestic assault by a habitual offender pursuant to 18 U.S.C. § 117 (“Count Five”). LaVictor was arrested on July 30, and arraigned a few days later by a magistrate judge who ordered that he have no contact with C.”
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