Quantums of Force: Dispelling PSUEDO Ambiguities of “Physical Force” Under the Lautenberg Amendment Through the Application of Canons of Construction

On October 2, 2012, Zina Haughton called the police from a gas station. She was not wearing any shoes, her makeup was running, her shirt was ripped, and it looked like she was crying. She told police officers that her husband, Radcliffe Haughton, “forcefully removed her cell phone from her bra.” Police officers noticed and asked Zina about the scrapes and swelling on her face, but she refused to acknowledge the injuries.

This was not Zina’s first experience of domestic violence at the hands of her husband. Earlier in 2011, Radcliffe was charged with disorderly conduct after police officers responded to a 911 call and saw him pointing a gun at Zina. The charges were dropped when the responding officer did not appear in court.Six days later, Zina sought a restraining order against Radcliffe. The order described his threats to kill her if she ever left him. Even though the court ordered Radcliffe to turn over any firearms in his custody, police officials did not confirm his compliance. His Google Plus profile picture shows him pointing a firearm towards the camera.