Screws v. United States

Incident Summary & Facts

Screws, the sheriff of Baker County, Georgia, enlisted a city policeman (Jones) and a special deputy (Kelley) to arrest Robert Hall, a young Black man about thirty years old, late at night at his home on a warrant for theft of a tire. Hall was handcuffed and driven to the courthouse. As he got out of the car in the courthouse square, the three officers began beating him with their fists and with “a solid-bar blackjack about eight inches long and weighing two pounds.” They claimed Hall had reached for a gun and used insulting language. After Hall, still handcuffed, was knocked to the ground, they kept beating him for fifteen to thirty minutes until he was unconscious. He was dragged feet first into the jail and died at a hospital within the hour. There was evidence that Screws held a grudge against Hall and had threatened to “get” him.

The officers were federally prosecuted under § 20 of the Criminal Code (now 18 U.S.C. § 242) for willfully depriving Hall, under color of law, of Fourteenth Amendment due process rights, and for conspiracy. The jury was instructed that the officers acted illegally if they beat Hall when it was not “necessary to make the arrest effectual or necessary to their own personal protection.” They were convicted, and the Fifth Circuit affirmed. The Supreme Court granted certiorari. This was a criminal prosecution of officers, not a civil excessive-force suit, and it was decided under the Fourteenth Amendment’s Due Process Clause rather than the Fourth Amendment.

Core Legal Issue

Whether § 20, which criminalizes willful deprivation of constitutional rights under color of law, is unconstitutionally vague as applied to Fourteenth Amendment due process rights; what “willfully” requires; and whether officers who violate state law in carrying out an arrest act “under color of” law.

The Holding

In a plurality opinion by Justice Douglas, the Court upheld § 20 by reading “willfully” to require a specific intent to deprive a person of a constitutional right made definite by the Constitution or court decisions, and held that the officers acted “under color of” law. Because the jury was not instructed on that specific intent, the convictions were reversed and the case remanded for a new trial.

The Court’s Analysis:

• Vagueness saved by specific intent: Read broadly, § 20 would leave officers “loose at their own risk on a vast uncharted sea” of changing due process law. Requiring a “specific intent to deprive a person of a federal right made definite by decision or other rule of law” gives fair warning.
• Intent can be inferred: Officers who “act as prosecutor, jury, judge, and executioner” deprive a prisoner of a trial. The jury may infer purpose from “the malice of petitioners, the weapons used in the assault, its character and duration, the provocation, if any, and the like.”
• Under color of law: “Misuse of power, possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law,” is action under color of law (following United States v. Classic). Officers authorized to arrest who use excessive force “overstep” their authority but still act under color of law.
• The failure to instruct on willfulness was a fundamental error that the Court noticed on its own, even though the defense raised no objection.
• Rutledge, J., would have affirmed but voted to reverse so the case could be decided. Murphy, J., dissented, arguing the right to life was plain and the conviction should stand. Roberts, Frankfurter, and Jackson, JJ., dissented, arguing the officers did not act under color of law and the statute was too vague.