Screws v. United States

Supreme Court of United States
325 U.S. 91 (1945)

ELI5:

Rule of Law:

For a state actor to be convicted under 18 U.S.C. § 52 for depriving an individual of a constitutional right, the government must prove the actor had a specific intent to deprive the person of a federal right made definite by the Constitution or federal law.

Facts:

Sheriff Claude Screws of Baker County, Georgia, enlisted policeman Frank Jones and special deputy Jim Bob Kelley to arrest Robert Hall, a young Black man, on a warrant for tire theft.
The officers arrested Hall late at night at his home, handcuffed him, and transported him by car to the courthouse.
As Hall exited the car at the courthouse square, Screws, Jones, and Kelley began beating him with their fists and a two-pound, solid-bar blackjack.
The officers continued to beat Hall for fifteen to thirty minutes after he was on the ground, until he was unconscious.
Hall was then dragged feet-first into the jail and left on the floor.
Hall was taken to a hospital where he died within an hour without regaining consciousness.
There was evidence that Sheriff Screws held a grudge against Hall and had previously threatened to 'get' him.

Procedural Posture:

The United States government indicted Sheriff Screws and officers Jones and Kelley in the U.S. District Court for violating § 20 of the Criminal Code.
The case was tried before a jury, which found the defendants guilty on both counts.
The defendants (appellants) appealed their convictions to the United States Circuit Court of Appeals for the Fifth Circuit.
The Circuit Court of Appeals (appellee being the United States) affirmed the judgment of the trial court, with one judge dissenting.
The petitioners (Screws, et al.) successfully petitioned the Supreme Court of the United States for a writ of certiorari.

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Issue:

To obtain a conviction under § 20 of the Criminal Code (18 U.S.C. § 52), which criminalizes the willful deprivation of constitutional rights under color of law, must the government prove that the defendant acted with a specific intent to deprive the victim of a known federal right?

Opinions:

Majority - Justice Douglas

Yes. To avoid being unconstitutionally vague, § 20 requires proof of a specific intent to deprive a person of a federal right made definite by the express terms of the Constitution, laws of the United States, or decisions interpreting them. The statute's use of the word 'willfully' implies an act done with a bad purpose to disregard the law. If the statute were interpreted to punish any act that a court later deemed a violation of due process, it would lack an ascertainable standard of guilt and would be a trap for law enforcement officers acting in good faith. The jury instruction in this case was erroneous because it only required a finding of a generally bad purpose (using more force than necessary), not the specific intent to deprive Hall of a constitutional right, such as the right to a trial by a court rather than by ordeal. Therefore, the conviction must be reversed and the case remanded for a new trial with proper instructions.

Dissenting - Justice Roberts

No. The conviction should be reversed outright because the officers did not act 'under color of law' and the statute is unconstitutionally vague. An officer acts 'under color of law' only when purporting to enforce an unconstitutional state law, not when violating a valid state law, as the officers did here by committing murder or manslaughter. This was a local crime that should be prosecuted by Georgia, not the federal government. Furthermore, § 20 is unconstitutionally vague because the scope of rights 'secured by the Constitution' is indefinite and constantly changing. Adding a requirement that the violation be 'willful' cannot make a vague prohibition definite; it is circular to require a person to willfully violate a right that is not clearly defined.

Dissenting - Justice Murphy

No. The conviction should be affirmed because the statute is not unconstitutionally vague as applied to this case. The right not to be deprived of life without due process of law is a fundamental and unambiguous constitutional right that any law officer would understand. The officers' act of beating a man to death was such a flagrant violation of this basic right that they had fair warning their conduct was a federal crime. Speculating about vagueness in other potential applications of the statute is irrelevant when the conduct here is so clearly prohibited. A new trial on the technical issue of willfulness is unnecessary given the overwhelming evidence that the officers acted with, at minimum, a wanton disregard for human life and constitutional rights.

Concurring - Justice Rutledge

No. While personally agreeing with Justice Murphy that the conviction should be affirmed, I concur in the judgment to reverse and remand for a new trial in order to prevent a stalemate and allow for a dispositive judgment by the Court. The statute is constitutional and the officers' brutal actions clearly fell within its scope as a willful deprivation of life under color of law. However, since the Court is fractured and unable to form a majority to affirm, and my views on disposition are closer to those of Justice Douglas than to the dissenting justices who seek outright reversal, I cast my vote with the Douglas opinion to ensure the case is resolved and remanded for a new trial.

Analysis:

Screws v. United States is a landmark case that saved a key federal civil rights statute from being struck down as unconstitutionally vague. By interpreting 'willfully' to require specific intent to deprive a person of a known constitutional right, the Court created a high evidentiary bar for prosecutors but preserved a vital tool for the federal prosecution of state officials who abuse their power. This 'specific intent' standard makes it difficult to prosecute officers for constitutional violations unless their intent is clear, but it established the principle that egregious official misconduct that deprives individuals of rights like a fair trial can be a federal crime. The decision affirmed federal power to protect civil rights against abuse by state actors, a foundational concept for later civil rights litigation and legislation.

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