## Facts

- Sheriff Mack Claude Screws and two other Georgia officers arrested Robert Hall, a Black man, at night on a warrant alleging theft of a tire.
- Hall was handcuffed and transported to the courthouse.
- As Hall exited the car, the officers beat him with fists and a metal blackjack; they continued beating him while he was handcuffed and on the ground.
- The beating lasted approximately 15–30 minutes, leaving Hall unconscious; officers dragged him into the jail and left him dying.
- Hall was taken to a hospital and died within an hour without regaining consciousness.
- Evidence indicated Screws held a grudge against Hall and had threatened to “get” him.
- A federal indictment charged a substantive violation and a conspiracy, alleging that, under color of state law, the officers willfully deprived Hall of Fourteenth Amendment rights, including the right not to be deprived of life without due process.

## Issues

1. Whether the federal civil-rights criminal statute (then § 20, now 18 U.S.C. § 242) was unconstitutionally vague as written, or could be sustained through a narrowing construction.
2. What “willfully” requires under § 242, including whether the government must prove a specific intent to deprive a person of a federal constitutional right rather than merely an intent to commit the assault.
3. Whether the trial court’s jury instructions improperly omitted the specific-intent element, and whether the Supreme Court could correct that omission despite the lack of a preserved objection.
4. Whether officers who abuse their authority during an arrest nonetheless act “under color of law” for purposes of § 242.

## Decision

- The Supreme Court reversed the affirmance of the convictions and ordered a new trial.
- The Court construed § 242 to require proof that the defendant specifically intended to deprive the victim of a federal right made definite by constitutional text, federal law, or authoritative judicial decisions.
- With that narrowing construction, the statute was upheld against the vagueness challenge as applied to Fourteenth Amendment rights.
- The Court held the jury instructions were fundamentally defective because they permitted conviction based on intentional assault and injury without requiring a finding that defendants acted with the purpose of depriving Hall of a federal right.
- The Court treated the omission of an essential element from the charge as fundamental error reviewable on its own motion.
- The Court held the conduct occurred “under color of law” because the officers acted in their official capacity while arresting and holding Hall, even though their conduct was criminal and abusive.

## Legal Principles

- A prosecution under 18 U.S.C. § 242 requires proof of a specific intent to deprive a person of a federal right that is clearly defined by the Constitution, federal statutes, or controlling judicial decisions.
- “Willfully” under § 242 is not satisfied by a general bad purpose or mere intent to do the physical acts; it requires a purpose to disobey or disregard the law by depriving the victim of a specific federal right.
- Specific intent may be inferred from circumstantial evidence, including the defendants’ malice, weapons used, duration and character of the assault, and surrounding circumstances.
- A jury charge that omits an essential element of the federal offense—here, specific intent to deprive a federal right—constitutes fundamental error warranting reversal even without a timely objection.
- Misuse of official power during an arrest can qualify as action “under color of law” when the officer’s authority supplies the means or pretense for the conduct.

## Conclusion

The Court sustained § 242 by narrowly construing “willfully” to require specific intent to deprive a clearly defined federal right, held that brutal abuse by arresting officers can occur under color of law, and reversed for a new trial because the jury was not instructed to find that specific intent.


Screws v. United States, 325 U.S. 91 (1945)