Whether the causation of physical injury or death necessarily requires the use of violent force

QUESTION PRESENTED As relevant here, the Armed Career Criminal Act (“ACCA”) defines “violent felony” as an offense that “has as an element the use, attempted use, or threatened use of physical force against the person of another.” 18 U.S.C. § 924(e)(2)(B)(i). In (Curtis) Johnson v. United States, 559 U.S. 133 (2010), the Court defined “physical force” as “violent force—that is, force capable of causing physical pain or injury to another person.” Jd. at 140 (emphasis in original). In United States v. Castleman, 572 U.S. 157 (2014), the Court left open whether “the causation of bodily injury necessarily entails violent force” under Johnson. Id. at 167, 170. In the decision below, the Eleventh Circuit affirmatively resolved that question. Deepening a circuit split, it held that the causation of injury or death necessarily requires violent force. And that is true, it held, even where the injury or death is caused by an act of omission, such as withholding food or medical care. The question presented is the one left open in Castleman: Whether the causation of physical injury or death necessarily requires the use of violent force. i