Screws v. United States
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325 U.S. 91 (1945)
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U.S. Supreme Court
Screws v. United States, 325 U.S. 91 (1945)
Screws v. United States
Argued October 20, 1944
Decided May 7, 1945
325 U.S. 91
1. Upon review of a judgment affirming the conviction, for violation of § 20 of the Criminal Code and conspiracy thereunto, of local law enforcement officers who arrested a negro citizen for a state offense and wrongfully beat him to death, the judgment is reversed with directions for a new trial. Pp. 325 U. S. 92-94, 325 U. S. 113.
Opinion of DOUGLAS, J., in which the CHIEF JUSTICE, MR. JUSTICE BLACK and MR. JUSTICE REED concur:
2. Section 20 of the Criminal Code, so far as it penalizes acts which "willfully" deprive a person of any right secured to him by the due process clause of the Fourteenth Amendment, is to be construed as requiring a specific intent to deprive of a right which has been made specific by the express terms of the Constitution or laws of the United States or by decisions interpreting them; and, as so construed, the section is not unconstitutional as lacking an ascertainable standard of guilt. P. 325 U. S. 101.
3. The trial court erred in not instructing the jury that, in order to convict, they must find that the defendants had the purpose to deprive the prisoner of a constitutional right. In determining whether that requisite bad purpose was present, the jury would be entitled to consider all the attendant circumstances -- the malice of the defendants, the weapons used in the assault, the character and duration of the assault, the provocation, if any, and the like. P. 325 U. S. 106.
4. Although no exception was taken to the trial court's charge, the error was so fundamental -- failure to submit to the jury the essential elements of the only offense on which the conviction could rest -- that this Court takes note of it sua sponte. P. 325 U. S. 107.
5. In making the arrest and in assaulting the prisoner, the defendants acted "under color of law," within the meaning of § 20 of the Criminal Code. P. 325 U. S. 107.
Defendants were officers of the law who had made an arrest, and it was their duty under the law of the State to make the arrest
effective. By their own admissions, they made the assault in order to protect themselves and to keep the prisoner from escaping.
140 F.2d 662, reversed.
CERTIORARI, 322 U.S. 718, to review a judgment affirming convictions for violation of § 20 of the Criminal Code and conspiracy.