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 reviewed whether New York's second-degree murder, which can be committed by omission, qualifies as a 'crime of violence' under 18 U.S.C. § 924(c). The case involved Salvatore Delligatti, who was convicted for recruiting gang members to commit murder using a firearm. The Court applied the categorical approach to determine if the offense involves the use of physical force. The Second Circuit's decision affirming that such offenses are crimes of violence was upheld.
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, involves the use of physical force against another person under § 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 Due Process is relevant to Delligatti v. United States
The case involves the interpretation of what constitutes a 'crime of violence' under federal law, which implicates due process rights in ensuring that laws are not vague and are applied consistently.
Syllabus excerpt (verbatim)Delligatti moved to dismiss his § 924(c) charge on the ground that the charge lacked the required predicate crime of violence, but the District Court denied his motion.
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).
The ordinary meaning of the term 'crime of violence' confirms that Congress meant for the elements clause to cover crimes of omission.