Screws v. United States
Citation
325 U.S. 91 (1945)
Facts
Claude Screws, a Georgia sheriff, arrested Robert Hall, a Black man, and beat him to death while handcuffed in the town square; Screws was charged under the predecessor statute to 18 U.S.C. § 242 for willfully depriving Hall of his constitutional rights under color of law.
Issue
Whether 18 U.S.C. § 242 is unconstitutionally vague, and if not, what mens rea the statute requires.
Holding
The Court upheld the constitutionality of § 242 but reversed Screws’s conviction on the ground that the jury was not properly instructed that the statute requires specific intent to deprive the victim of a constitutional right.
Rule
18 U.S.C. § 242 requires that the defendant act with specific intent — a purpose to deprive another of a constitutional right — under color of law; general criminal intent or willfulness in a generic sense is insufficient to establish the required mens rea.