2014 as it was considered to be at odds with the 2011 constitution. United States: United States v. Castleman (2014) challenged the application of the Domestic Violence Offender Gun Ban to misdemeanor convictions which did not involve "the use or attempted use of physical force". In a 9–0 decision, the United States Supreme Court held that Castleman's conviction of "misdemeanor domestic assault" did qualify as a "misdemeanor crime of domestic violence" under Tennessee state law. Specifically they held that the "'physical force' requirement is satisfied by the degree of force that supports a common-law battery conviction – namely, offensive touching" – thereby preventing him from possession of firearms. United States: McCullen v. Coakley, , was a United States Supreme Court case. The Court unanimously held that Massachusetts' 35-feet fixed abortion buffer zones, established via amendments to that state's Reproductive Health Care Facilities Act, violated the First Amendment to the U.S. Constitution because it limited free speech too broadly. Ecuador: In August 2014, a new criminal code came into force in Ecuador, and it no longer contains any marry-your-rapist laws. Portugal: Article 400 of the Portuguese penal code of 1886, which still functioned in post-colonial Mozambique until its replacement on 11 July 2014, stated that rapists who married their victim would not be punished. The law was not applied since independence in 1974. It was repealed in 2014. Ireland: The Protection of Life During Pregnancy Act 2013 ( was signed into law on 30 July by Michael D. Higgins, the President of Ireland; it commenced on 1 January 2014. The Protection of Life During Pregnancy Act 2013 Act No.35 of 2013; previously Bill No.66 of 2013) is an Act of the Oireachtas which defined the circumstances and processes within which abortion in Ireland could be legally performed. The Act gave effect in statutory law to the terms of the Constitution of Ireland as interpreted by the Supreme Court in the 1992 judgment Attorney General v. X (the "X case"). That judgment allowed for abortion where pregnancy endangers a woman's life, including through a risk of suicide. Ireland: P.P v. Health Service Executive was a 2014 case in the Irish High Court to rule on whether a pregnant woman (anonymised as "N.P.") who was brain dead ought to be kept on life support until the foetus was viable and could be delivered. In ruling for life support to be switched off, the