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 |
| Case history | |
| Procedural | 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 | |
| |
| 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,[citation needed] 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
- ^ Urofsky, Melvin I. (2004). "Mack Claude Screws". 100 Americans Making Constitutional History: A Biographical History. CQ Press. pp. 180–82.
{{cite book}}: External link in|chapterurl=|chapterurl=ignored (|chapter-url=suggested) (help) - ^ Chalmers, David Mark (2005). Backfire: How the Ku Klux Klan Helped the Civil Rights Movement. Rowman & Littlefield. p. 74.
- ^ 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.
- ^ 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.
{{cite journal}}: CS1 maint: multiple names: authors list (link) - Watford, Paul J. (2014). "Screws v. United States and the Birth of Federal Civil Rights Enforcement". Marquette Law Review. 98 (1): 465–486.
External links
- Text of Screws v. United States, 325 U.S. 91 (1945) is available from: Justia Library of Congress