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Screws v. United States

    Brief Fact Summary.

    Defendant was convicted of willfully depriving an individual of his rights under the due process clause of the Constitution based on the individual’s race and conspiracy of the same crime when he and two other officers arrested and beat a young African-American, causing his death. The court of appeals affirmed.

    Synopsis of Rule of Law.

    When a statute requires an individual to perform an action willfully, the individual must will not only the action, but also the consequences of that action.

    Facts.

    Screws (Defendant) and two other police officers in Georgia arrested Hall, a young African-American, for theft of tires. The police officers took Hall to the county court house and began to beat him with their fists and with an iron bar. Defendant claimed that Hall was trying to pull a gun on them, but evidence demonstrated that the officers beat Hall for at least fifteen minutes after he was handcuffed. Hall died from the incident. Defendant was charged with willfully depriving an individual of his rights under the due process clause of the Constitution based on the individual’s race and conspiracy of the same crime. The trial judge instructed the jury to find Defendant guilty of the crime if he willfully deprived Hall of his right to a trial by jury as guaranteed by the Fourteenth Amendment. The judge instructed the jury that Hall was guilty if they believed he wrongfully assaulted Hall and intended his injuries. Defendant was convicted of both the crime and conspiracy of the same crime. The circuit court of appeals affirmed his conviction. The United States Supreme Court granted certiorari.

    Issue.

    Whether an individual who acts with a generally bad purpose willfully intended every specific consequence of his actions.

    Held.

    No. Defendant’s conviction is reversed and the case is remanded for new trial. When a statute requires an individual to perform an action willfully, the individual must will not only the action, but also the consequences of that action.

    Dissent.

    Murphy, J.
    The majority opinion is giving the term willfully too specific a definition. Defendant willfully beat Hall and intended to cause him physical harm. His death naturally flows from this intent. Just because Defendant did not intend to deprive Hall of a trial by jury does not mean he should not be found guilty under the statute in question. If such a defense were allowed, individuals would very often claim that they did not intend the specific result of their actions and be found not guilty because they did not willfully commit the crime as required. This is a slippery slope, one we must stop here. Defendant’ conviction should be affirmed.

    Roberts, J.
    The majority opinion is giving the term willfully too specific a definition. Defendant willfully beat Hall and intended to cause him physical harm. His death naturally flows from this intent. Just because Defendant did not intend to deprive Hall of a trial by jury does not mean he should not be found guilty under the statute in question. If such a defense were allowed, individuals would very often claim that they did not intend the specific result of their actions and be found not guilty because they did not willfully commit the crime as required. This is a slippery slope, one we must stop here. Defendant’ conviction should be affirmed.

    Concurrence.

    (Rutledge, J.): State officials have a greater duty to know the law than do the general public. That being said, while there are certain rights that the due process clause of the Constitution specifically protects, there are also genuine questions as to whether there are other rights that the clause protects. Therefore, the statute in question is at least somewhat vague, and is unconstitutional. A statute is only constitutional if it allows individuals to know specifically what set of actions it is criminalizing. This statute does so with certain rights, but not with others. Accordingly, the statute is unconstitutional, and Defendant’s conviction should be overturned.

    Discussion.

    While Defendant and his cohorts’ actions were reprehensible, Defendant did not intend to deprive Hall of his constitutional right to be tried in a court of law when he beat Hall. A statute that delineates that the potential offender commit the crime willfully requires the individual not only to intend his actions, but also to intend the particular consequence of those actions. He must intend what he is doing and the direct result of what he is doing. Here, Defendant certainly intended to beat Hall and to cause him severe physical harm. However, he did not intend to deprive Hall of his constitutional right to a trial by jury in a court of law. In other words, Defendant was not thinking “This guy won’t ever go to court” as he was beating Hall. The jury instructions at the trial court were thus fundamentally incorrect, as they misinterpreted the meaning of the term willfully.


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