The D.C. Circuit has affirmed the denial of a motion to vacate a firearm-during-a-crime-of-violence conviction obtained against a man who fired multiple rounds at the White House, holding that his underlying conviction for willfully and maliciously injuring a dwelling within federal jurisdiction categorically involves the use of physical force against another's property.
Tracing the statute's roots to nineteenth-century arson law and the common-law offense of malicious mischief, the Court held that injuring a dwelling requires material impairment inflicted intentionally and for a wrongful purpose, and that the Supreme Court's decisions in Johnson v. United States and Delligatti v. United States establish that intentionally causing such impairment necessarily involves the use of physical force. The Court also held the statute's historical pedigree confirms it reaches only injury to someone else's property, not one's own, satisfying the force clause's requirement that the property belong to "another."
The full text of United States v. Ortega-Hernandez can be found here: https://media.cadc.uscourts.gov/opinions/docs/2026/09/24-3023-2190849.pdf