Law School Case Brief
Screws v. United States - 325 U.S. 91, 65 S. Ct. 1031 (1945)
When 18 U.S.C.S. § 52 is applied to the action of state officials, it should be construed so as to respect the proper balance between the States and the federal government in law enforcement. Violation of local law does not necessarily mean that federal rights have been invaded. The fact that a prisoner is assaulted, injured, or even murdered by state officials does not necessarily mean that he is deprived of any right protected or secured by the Constitution or laws of the United States. The Fourteenth Amendment did not alter the basic relations between the States and the national government. The national government is one of delegated powers alone. Under the federal system the administration of criminal justice rests with the States except as Congress, acting within the scope of those delegated powers, has created offenses against the United States. It is no more the duty or within the power of the United States to punish for a conspiracy to falsely imprison or murder within a State, than it would be to punish for false imprisonment or murder itself. It is only state action of a "particular character" that is prohibited by the Fourteenth Amendment and against which the Amendment authorizes Congress to afford relief.
Police officers arrested Robert Hall, a young negro who was a citizen of the State of Georgia. Hall was handcuffed and taken by car to the court house. As Hall alighted from the car at the court-house square, the police officers began beating him with their fists and with a solid-bar blackjack weighing about two pounds; the police officers’ act resulted in Hall’s death. Thereafter, the police officers were charged with violation of 18 U.S.C.S. § 52, which made it an offense for any person under color of law to willfully deprive any person of any rights and privileges protected by the Constitution, by reason of the person’s color or race. The indictment charged that police officers, acting under color of the laws of Georgia, “willfully” caused Hall to be deprived of “rights, privileges, or immunities secured or protected” to him by the Fourteenth Amendment, i.e., the right not to be deprived of life without due process of law. The jury returned a verdict of guilty. The Circuit Court of Appeals affirmed the judgment of conviction. The police officers petitioned the United States Supreme Court, contending that 18 U.S.C.S. § 52 was unconstitutional, insofar as it made criminal acts in violation of the due process clause of the Fourteenth Amendment.
Was 18 U.S.C.S. § 52 unconstitutional?
The Court held that while the statute in question was not unconstitutionally vague, its enforcement did not make all torts of state officials federal crimes. According to the Court, only specific acts done willfully, under color of state law, and which deprived a person of some right secured by the Constitution or laws of the United States were prescribed by 18 U.S.C.S. § 52 The Court further held, however, that while 18 U.S.C.S. § 52 survived constitutional challenge, a new trial was indicated as the instruction given to the jury did not convey that a finding of willfulness was necessary for guilt under the statute. The Court noted that while normally when no exception was taken to a jury instruction during trial, such issue was unpreserved for review; however, review was required when the error was fundamental. Where the essential elements of the offense on which the convictions rested were not submitted to the jury, the error was fundamental.
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