Friday, November 15, 2013

Screws v. United States case brief

Screws v. United States case brief summary
325 U.S. 91 (1945)

Petitioners, police officers convicted of beating to death a suspect in their custody, sought review of their convictions by the United States Circuit Court of Appeals for the Fifth Circuit under 18 U.S.C.S. § 52, which criminalized willful deprivations of a citizen's rights.

Petitioners contended that 18 U.S.C.S. § 52 was unconstitutional.

  • On appeal, the convictions were reversed and a new trial was ordered. 
  • In its opinion, the Supreme Court stated that while § 52 was not unconstitutionally vague, its enforcement did not make all torts of state officials federal crimes. 
  • 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 § 52. 
  • The Court further held, however, that while § 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.

The Court reversed the judgment and ordered a new trial as the failure to include the willfulness component in the jury instruction necessitated a new trial, although the statute under which petitioners were convicted survived a constitutional challenge.

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