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 second-degree murder 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, even by omission, involves the use of physical force. The decision affirms the lower court\'s ruling that Delligatti\'s actions met the statutory definition.
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.
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Why Judicial Review is relevant to Delligatti v. United States
The Court is interpreting the statutory definition of 'crime of violence' under federal law, which involves reviewing and applying legal standards to determine the applicability of the statute.
Syllabus excerpt (verbatim)To determine whether an offense falls within § 924(c)(3)(A)'s 'elements clause,' the Court applies the categorical approach.
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Why Procedural Due Process is relevant to Delligatti v. United States
The case involves the interpretation of statutory language that affects criminal liability and sentencing, implicating procedural fairness in how laws are applied.
Syllabus excerpt (verbatim)Delligatti moved to dismiss his § 924(c) charge on the ground that the charge lacked the required predicate crime of violence.
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Why Void for Vagueness is relevant to Delligatti v. United States
The challenge involves the clarity of the statutory definition of 'crime of violence,' which could render the statute vague if not clearly defined.
Syllabus excerpt (verbatim)Delligatti argued that a VICAR offense predicated on New York second-degree murder is not a crime of violence under § 924(c)'s elements clause because homicide under New York law can be committed by 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).
Delligatti also argues that an offender who causes harm by omission does not make 'use' of physical force 'against the person . . . of another.'
