Screws v. United States

Brief Fact Summary.

Screws was convicted of violating the due process clause of the fourteenth amendment and conspiracy of the same crime when he beat an African-American to his death after arresting him.

Synopsis of Rule of Law.

A person must will an action as well as the consequences of the action.

Facts.

Screws, a police officer, arrested an African-American named Hall, claiming that Hall attempted to pull a gun on him. Hall was continuously beaten fifteen minutes after he was handcuffed. Hall died from his injuries. Screws was convicted under the due process clause of the fourteenth amendment by the district court, and the circuit court of appeals affirmed.

Issue.

Whether a person who acts with a bad purpose intends all the consequences of his actions?

Held.

No. The judgment of the lower courts are reversed. Screws did not intend to deprive Hall of his right to a trial when Hall was beaten. Screws intended to beat Hall and cause injury to Hall, but did not intend to kill Hall, depriving Hall of his right to a trial by jury.

Dissent.

(Murphy, J.) Screws willfully deprived Hall of his constitutional right because he beat Hall, which naturally resulted in Hall’s death. As an officer of the law, Screws cannot use ignorance of the law as a defense.

(Roberts, J.) Screws should be convicted under the statute because not convicting Screws would allow every defendant to be found not guilty if they did not intend the specific result of their actions.

Concurrence.

(Rutledge, J.) The statute is unconstitutional because it does not allow individual citizens to know what actions specifically constitute criminal activity.

Discussion.

The charged must intend the actions of his crime as well as the specific consequences of his crime.