Plain-English summary
Court: Intentionally causing injury or death counts as 'use' of physical force under §924(c)(3)(A)
The Court held that knowingly or intentionally causing injury or death—by action or omission—constitutes the “use” of physical force under federal law 18 U.S.C. §924(c)(3)(A). The decision affirms the Second Circuit and was issued in Delligatti v. United States.
Why this matters
This ruling clarifies which prior convictions count as “crimes of violence” for a wide range of federal sentencing and statutory provisions that impose enhanced penalties when a conviction involves use of physical force. It affects who can face mandatory additional penalties under §924(c) and similar federal statutes and reduces uncertainty among lower courts about how to treat offenses based on intentional harm or omissions.
Who may feel it
- Defendants with prior convictions for offenses that require intentionally causing injury or death
- Federal prosecutors seeking sentence enhancements under 18 U.S.C. §924(c) and related statutes
- Federal courts deciding whether predicate offenses qualify as crimes of violence
- Defense attorneys and public defenders advising clients about sentencing exposure
Key questions
- Does a felony that requires proof of intentionally causing bodily injury or death qualify as a “crime of violence” under 18 U.S.C. §924(c)(3)(A)?