Screws v. United States

Screws v. United States
Argued October 20, 1944
Decided May 7, 1945
Full case name Mack Claude Screws v. United States
Citations 325 U.S. 91 (more)
65 S. Ct. 1031; 89 L. Ed. 2d 1495
Procedural history Certiorari to the United States Court of Appeals for the Fifth Circuit
Holding
In general, a conviction under 18 U.S.C. §242 requires proof of the defendant's specific intent to deprive the victim of a federal right. In Screws, the prosecution has failed to prove such deliberate intent.
Court membership
Chief Justice
Harlan F. Stone
Associate Justices
Owen Roberts · Hugo Black
Stanley F. Reed · Felix Frankfurter
William O. Douglas · Frank Murphy
Robert H. Jackson · Wiley B. Rutledge
Case opinions
Plurality Douglas, joined by Stone, Black, Reed
Concurrence Rutledge
Dissent Murphy
Dissent Roberts, joined by Frankfurter, Jackson

Screws v. United States, 325 U.S. 91 (1945), also known as the Screws precedent, was a 1945 Supreme Court case that made it difficult for the federal government to bring prosecutions when local government officials killed African-Americans in an extra-judicial manner.

Claude Screws, the sheriff of Baker County, Georgia,[1] arrested Robert "Bobby" Hall, an African-American, on January 29, 1943. Hall had allegedly stolen a tire, and was alleged to have tried to fight back against Screws and two of his deputies during the arrest.[2] Hall was arrested at his home.[3] Screws then beat Hall to death.

The local U.S. attorney then convened a grand jury which indicted Screws on charges of violating Hall's civil rights. Screws was then convicted at the federal court house in Albany, Georgia. The conviction was upheld by the Circuit Court and then appealed to the Supreme Court. While the case was moving through the courts Screws was reelected as sheriff by a very wide margin.

The Supreme Court, in a decision authored by William O. Douglas ruled that the federal government had not shown that Screws had the intention of violating Hall's civil rights when he killed him. This ruling greatly reduced the frequency with which federal civil rights cases were brought over the next few years.[4]

See also

References

  1. ↑ Urofsky, Melvin I. (2004). "Mack Claude Screws". 100 Americans Making Constitutional History: A Biographical History. CQ Press. pp. 180–82.
  2. ↑ Chalmers, David Mark (2005). Backfire: How the Ku Klux Klan Helped the Civil Rights Movement. Rowman & Littlefield. p. 74.
  3. ↑ Branch, Taylor (1988). Parting the Waters: American in the King Years, 1954–63. New York: Simon and Schuster. p. 408. ISBN 0-671-46097-8.
  4. ↑ Waldrep, Christopher (2001). Racial Violence on Trial: A Handbook with Cases, Laws and Documents. p. 76.

Further reading

  • Cohen, Julius (1946). "The Screws Case: Federal Protection of Negro Rights". Columbia Law Review. 46 (1): 94–106. JSTOR 1118266.
  • Putzel, Henry, Jr. (1951). "Federal Civil Rights Enforcement: A Current Appraisal". University of Pennsylvania Law Review. 99 (4): 439–454. JSTOR 3309630.
  • Watford, Paul J. (2014). "Screws v. United States and the Birth of Federal Civil Rights Enforcement". Marquette Law Review. 98 (1): 465–486.
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