Delligatti v. United States (No. 23-825)
Summary
The Supreme Court case Delligatti v. United States (2025) addresses whether causing bodily harm by omission (failing to act) constitutes the "use of physical force" under 18 U.S.C. §924(c)(3)(A), which defines a "crime of violence." The Court held that it does, affirming the Second Circuit's decision. This ruling clarifies the scope of "crime of violence" to include intentional harm caused by inaction, impacting sentencing for related federal offenses.
Expected Effects
This decision broadens the definition of "crime of violence" under federal law. It will likely lead to more defendants facing enhanced sentences under 18 U.S.C. §924(c) when their underlying crime involved the knowing and intentional causation of harm, even through omission. This could affect various federal crimes where the "crime of violence" definition is relevant.
Potential Benefits
- Clarifies the definition of "crime of violence," providing more consistent application of sentencing guidelines.
- Potentially deters individuals from causing harm through intentional neglect or omission.
- Ensures that individuals who intentionally cause harm, regardless of the means, are held accountable under federal law.
- Upholds the principle that intentional harm, whether by action or inaction, can constitute a violent crime.
- Reinforces the importance of legal duties and the consequences of failing to fulfill them when such failure leads to harm.
Most Benefited Areas:
Potential Disadvantages
- Broadens the scope of federal criminal law, potentially leading to unintended consequences in its application.
- May lead to harsher sentences for individuals whose actions were primarily omissions, even if their intent was not malicious.
- Could create challenges in distinguishing between intentional omissions and negligence, potentially leading to unjust convictions.
- May disproportionately affect individuals in caregiving roles, where legal duties are more pronounced.
- Could lead to increased litigation as defendants challenge the application of this broadened definition to their specific cases.
Constitutional Alignment
The ruling aligns with the legislative power granted to Congress under Article I, Section 8, to define and punish offenses against the United States. The Court's interpretation of 18 U.S.C. §924(c)(3)(A) does not appear to infringe upon any specific constitutional right. However, some may argue that it stretches the definition of "use of physical force" beyond its original intent, potentially raising due process concerns under the Fifth Amendment if applied too broadly or vaguely.
Impact Assessment: Things You Care About ⓘ
This action has been evaluated across 19 key areas that matter to you. Scores range from 1 (highly disadvantageous) to 5 (highly beneficial).