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 18 U.S.C. §924(c)(3)(A). This means that crimes that can be committed by omission, such as New York second-degree murder, still qualify as "crimes of violence" under the elements clause of §924(c).

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