No. 23-825October Term 2024Decided Mar 21, 2025
Salvatore Delligatti, Petitioner v. United States
The Supreme Court held that a crime requiring proof of bodily injury or death constitutes a "crime of violence" under federal law, even if the crime can be committed through inaction or omission rather than an affirmative act.
Case status
- Current stage
- Decided
- Latest event
- Decision released Mar 21, 2025
- What it's about
The Supreme Court held that a crime requiring proof of bodily injury or death constitutes a "crime of violence" under federal law, even if the crime can be committed through inaction or omission rather than an affirmative act. The Court reasoned that intentionally causing physical harm, regardless of the method, necessarily involves the use of physical force.
Question presented
Does a crime that requires proof of bodily injury or death, but which can be committed by failing to take action, have as an element the use, attempted use, or threatened use of physical force?
- Case path
United States Court of Appeals for the Second Circuit / Decision released Mar 21, 2025
- Area
Decided Supreme Court case
Documents
Related cases




Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Mar 30, 2026
- Method
- Methodology
Primary materials8
Supreme Court docket 23-825
docket | Mar 30, 2026
Primary case document
Supreme Court document | Mar 30, 2026
CourtListener docket record
docket | Mar 30, 2026
Questions Presented
brief | Mar 8, 2026
Delligatti
opinion | Mar 21, 2025
opinion
opinion | Mar 21, 2025
Oral Arguments - Delligatti
audio | Nov 12, 2024
Petition
brief | Jan 29, 2024