Delligatti v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Delligatti v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Delligatti v. United States.
In Delligatti v. United States, the Supreme Court addressed whether New York's second-degree murder, which can be committed by omission, qualifies as a 'crime of violence' under 18 U.S.C. § 924(c). The Court applied the categorical approach and concluded that intentional causation of injury or death involves the use of physical force. The decision affirmed the Second Circuit's ruling that such offenses fall within the elements clause of § 924(c).
Holding
The single most important “bottom line” of what the Court decided in Delligatti v. United States.
The Court held that the knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the 'use' of 'physical force' against another person within the meaning of § 924(c)(3)(A).
Constitutional Concepts
These are the Constitution-related themes that appear in Delligatti v. United States. Click a concept to see other cases that involve the same idea.
-
Why Substantive Due Process is relevant to Delligatti v. United States
The case involves the interpretation of what constitutes a 'crime of violence' under federal law, which implicates substantive due process principles regarding the definition and application of criminal statutes.
Syllabus excerpt (verbatim)The knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the 'use' of 'physical force' against another person within the meaning of § 924(c)(3)(A).
-
Why Void for Vagueness is relevant to Delligatti v. United States
The case addresses whether the statutory definition of a 'crime of violence' is sufficiently clear, which relates to the void for vagueness doctrine.
Syllabus excerpt (verbatim)The ordinary meaning of the term 'crime of violence' confirms that Congress meant for the elements clause to cover crimes of omission.
Key Quotes
Short excerpts from the syllabus in Delligatti v. United States that support the summary and concepts above.
The knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the 'use' of 'physical force' against another person within the meaning of § 924(c)(3)(A).
It is impossible to deliberately cause physical harm without the use of physical force under § 924(c).
The ordinary meaning of the term 'crime of violence' confirms that Congress meant for the elements clause to cover crimes of omission.