On June 2, 2014, the U.S. Supreme Court ruled in Bond v. United States that the Chemical Weapons Convention Implementation Act of 1998 (the Act), which implements the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction and makes a federal crime the use or possession of a chemical weapon, did not apply to a “purely local” assault involving the use of chemicals in Pennsylvania.  Petitioner Carol Anne Bond, a microbiologist, had spread toxic chemicals on the property of her husband’s mistress and subsequently pled guilty to, inter alia, two counts of possessing and using a chemical weapon in violation of § 229 of the Act.  The Court ruled that the Act, which contains no clear indication that it should intrude on State responsibility over local criminal activity, “does not cover the unremarkable local offense at issue.”