Salvatore Delligatti, Petitioner v. United States

The Supreme Court ruled 7-2 that a crime requiring proof of bodily injury or death is a crime of violence, even if it is committed by failing to act. The Court decided that intentionally causing harm through an omission, such as a parent refusing to feed a child, still involves the use of physical force under federal law.

This decision ensures that serious crimes like murder or attempted murder remain classified as violent crimes even when the defendant uses inaction as their weapon. It prevents defendants from receiving shorter sentences by arguing that their failure to act did not technically involve physical force.

The case centers on the definition of a crime of violence under federal law, which often triggers much harsher penalties. For years, courts have debated whether the term use of force requires an affirmative physical movement or simply the intentional causation of injury.

Justice Clarence Thomas wrote the 7-2 majority opinion, joined by six other justices. Justice Neil Gorsuch filed a dissenting opinion, which Justice Ketanji Brown Jackson joined.

“The knowing or intentional causation of bodily injury necessarily involves the use of physical force.”

The Supreme Court held that intentionally causing death or injury through inaction counts as using physical force under federal sentencing laws.

Lower courts will now apply this rule to various federal crimes to determine if they qualify for sentencing enhancements. Prosecutors will likely use this precedent to ensure that defendants charged with violent omissions face the same penalties as those who commit affirmative acts.

The dispute was whether a crime committed by omission (failing to act) can be considered a crime of violence. The Court had to decide if causing harm through inaction involves the use of physical force.

Defendants convicted of crimes of violence face significantly longer prison terms under federal law. This ruling ensures that those who plan murders or cause death through neglect cannot avoid these tougher sentences.

The Court established that the intentional causation of injury or death necessarily involves the use of physical force. This rule applies regardless of whether the harm was caused by an act or an omission.

The case will return to the lower courts to finalize the judgment based on this ruling. Judges across the country will begin applying this definition to other federal criminal cases immediately.

The ruling follows a trend of the Court focusing on the results of a defendant's actions rather than the specific method used. It reinforces a broad reading of what constitutes violent conduct in federal law.