Whether a criminal statute that prohibits the intentional causation of bodily injury to another 'by any means,' including omissions, is a violent felony for purposes of the Armed Career Criminal Act

QUESTION PRESENTED Petitioner Sean Mitchell was sentenced under the Armed Career Criminal Act (ACCA) to a mandatory minimum sentence of 15 years in prison. If the ACCA had not applied, he would have been subject to the 10-year statutory maximum sentence otherwise applicable to 18 U.S.C. § 922(g) offenses. The parties disagreed about two prior convictions under Virginia Code § 18.2-51, and whether they were ACCA “violent felonies.” Violent felonies for purposes of the ACCA include any prior conviction that “has as an element the use, attempted use, or threatened use of physical force against the person of another.” 18 U.S.C. § 92.4(e)(2)(B)@). Virginia Code § 18.2-51 prohibits the intentional causation of bodily injury to another person “by any means.” The question presented is: Whether a criminal statute that prohibits the intentional causation of bodily injury to another “by any means,” including omissions, is a violent felony for purposes of the Armed Career Criminal Act.