Delligatti v. United States
In brief
A crime requiring knowing or intentional injury or death counts as a crime of violence under §924(c)(3)(A), whether committed through action or omission.
- Where it stands
- Decided
Decided 7-2 · March 21, 2025 · Opinion by Justice Thomas
- 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.
- Who it affects
- The decision allows federal courts to treat injury-or-death crimes committed by omission (a failure to act when there is a duty) as crimes of violence under §924(c)(3)(A).
Summary: written with AI from the case record.
What it's about
The Court reasoned that intentionally causing physical harm, regardless of the method, necessarily involves the use of physical force.
The case addresses how federal use-of-force language applies when a crime causes bodily injury or death through inaction rather than an affirmative act.
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?
What the Court decided
Holding
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). 83 F. 4th 113, affirmed.
- Result
- Affirmed
The vote
From the opinions
“The knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the “use” of “physical force” against another person”
“Section 924(c)(3)(A) may reach many crimes, but it does not reach crimes of omission.”
What's next
Lower courts must apply this interpretation when deciding whether qualifying injury-or-death crimes are crimes of violence under §924(c)(3)(A). Federal prosecutors, defendants, and agencies will assess affected cases under the Court's rule.
Why it matters
For example, a person charged with intentionally causing harm by failing to provide required care may face that classification.
Documents
Docket activity
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More questions
- What did the Supreme Court rule in Delligatti?
- The Court ruled that knowingly or intentionally causing injury or death uses physical force under §924(c)(3)(A), including when caused by omission.
- Who won Delligatti v. United States?
- The United States won. The Court affirmed the Second Circuit's decision by a 7-2 vote.
- What does Delligatti mean for people charged with omission crimes?
- An omission crime requiring knowing or intentional injury or death can be classified as a federal crime of violence.
- Is the omission rule still the law after Delligatti?
- Yes. The Court said knowing or intentional injury or death involves physical force whether caused by an act or omission.
- What happens next after Delligatti?
- Lower courts must follow the decision in cases involving §924(c)(3)(A) and injury or death caused by action or omission.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.