What did the Supreme Court decide in Stands Alone (21‑6826) regarding § 111 and the common‑law assault element?

1. What the statutory dispute is about: § 111’s language and the “assault” question

The legal fight centers on 18 U.S.C. § 111, which criminalizes whoever “forcibly assaults, resists, opposes, impedes, intimidates, or interferes with” certain federal officers and then heightens punishment where bodily injury results (the (a) and (b) subsections) ^[4]. The controversy asks whether “assault” in that disjunctive statutory list must be read as the common‑law tort/crime of assault—with its element of putting a person in reasonable apprehension of imminent harmful contact—or whether Congress instead created a composite offense that reaches a broader range of forcible conduct listed in the statute ^{[5] [4]}.

2. How the Seventh Circuit decided the case below

The Seventh Circuit rejected Todd Stands Alone’s narrow reading, holding that a conviction under § 111(a) and (b) does not require “assault” as an essential element; the government may prove any one of the statute’s six listed acts (assault, resist, oppose, impede, intimidate, or interfere) together with bodily injury to obtain a § 111(b) conviction ^[2]. The court applied statutory text and precedent to conclude that the disjunctive list signals Congress intended to proscribe a range of conduct beyond the common‑law assault definition ^{[6] [2]}.

3. What the petitioner and amici argued to the Supreme Court

Stands Alone’s cert petition asked the Supreme Court to decide whether “common‑law simple assault” is an essential element of § 111(b), contending that an indictment that fails to allege assault is defective ^[1]. Supporting briefs from amici pressed the traditional common‑law definition—an intentional act causing reasonable apprehension of harmful contact—and urged the Court to adopt that element as required by § 111, invoking the related‑statute canon and historical practice ^{[7] [5]}. Those briefs argued that nothing in § 111’s text overcomes the presumption that Congress used “assault” with its common‑law meaning ^[7].

4. What the supplied materials show about Supreme Court action (and what they do not)

The docket and briefing in the record confirm certiorari litigation (No. 21‑6826) and competing positions, but do not contain a Supreme Court opinion resolving the question; therefore, the record here does not show a Supreme Court decision for or against importing the common‑law assault element into § 111 ^{[6] [1]}. Any claim that the high court definitively ruled one way or the other is not supported by the sources provided; absent a Supreme Court opinion in these materials, the correct reading based on the supplied reporting is that the Seventh Circuit’s interpretation stands in that circuit ^{[2] [3]}.

5. Why this question matters and the contours of disagreement

If a court treats “assault” in § 111 as the common‑law offense, prosecutions would be constrained by the assault element and indictments would need to plead and prove that mental‑state/ apprehension component; conversely, the Seventh Circuit’s reading permits convictions when the government proves any listed act plus bodily injury, a broader prosecutorial scope that some amici say departs from historical meaning ^{[2] [7]}. Historical decisions like Ladner show Congress long has lumped assault with other offensive actions in § 111’s statutory line ^[8], a fact the government and some lower courts use to argue against reading a standalone common‑law element into the modern statute ^{[6] [4]}.

6. Bottom line

Based on the documents provided, the Supreme Court’s definitive resolution is not in the record; the Seventh Circuit holds that § 111(b) does not require the common‑law assault element, the petitioner and amici asked the high court to reverse that view and adopt the common‑law element, and the statutory text and legislative history cited by both sides provide the basis for competing, plausible readings ^{[2] [1] [7] [4]}. Any authoritative statement about the Supreme Court’s decision requires a Court opinion or later reporting that is not contained among these sources.