In 1996, Congress passed the Lautenberg Amendment to prevent domestic violence shooting deaths. The Lautenberg Amendment works the same way as the felon-in-possession law: any individual who has previously been convicted of a qualifying predicate crime is prohibited from possessing a gun. For the felon-in-possession law, any felony is a predicate offense. For the Lautenberg Amendment, “misdemeanor crimes of domestic violence” are predicate offenses; any crime that “has, as an element, the use . . . of physical force” qualifies as a misdemeanor crime of domestic violence. A circuit split has recently developed over what conduct constitutes the use of “physical force” for the purposes of the Lautenberg Amendment.