Screws v. United States

E362102

United States Supreme Court case civil rights case criminal law case

Screws v. United States is a 1945 U.S. Supreme Court decision that narrowly interpreted federal civil rights protections in prosecuting state officials for the brutal killing of a Black man, shaping the “willful intent” standard under 18 U.S.C. § 242.

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All labels observed (2)

Label	Occurrences
Screws v. United States, 325 U.S. 91 (1945)	2
Screws v. United States canonical	1

How this entity was disambiguated

This entity first appeared as the object of triple T3488659 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Screws v. United States
Context triple: [United States Supreme Court cases of the Stone Court, includesCase, Screws v. United States]

A. Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
B. Carpenter v. United States
Carpenter v. United States is a 2018 U.S. Supreme Court decision that held the government generally must obtain a warrant to access historical cell phone location records under the Fourth Amendment.
C. Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
D. Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
E. Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Screws v. United States
Target entity description: Screws v. United States is a 1945 U.S. Supreme Court decision that narrowly interpreted federal civil rights protections in prosecuting state officials for the brutal killing of a Black man, shaping the “willful intent” standard under 18 U.S.C. § 242.

A. Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
B. Carpenter v. United States
Carpenter v. United States is a 2018 U.S. Supreme Court decision that held the government generally must obtain a warrant to access historical cell phone location records under the Fourth Amendment.
C. Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
D. Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
E. Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
F. None of above. chosen

Statements (47)

Predicate	Object
instanceOf	United States Supreme Court case ⓘ civil rights case ⓘ criminal law case ⓘ
citation	325 U.S. 91 ⓘ
civilRightsImpact	illustrated limitations of federal criminal law in addressing Jim Crow–era racial violence ⓘ
constitutionalProvisionInvolved	Due Process Clause ⓘ surface form: Due Process Clause of the Fourteenth Amendment Fourteenth Amendment ⓘ surface form: Fourteenth Amendment to the United States Constitution
constitutionalRightAtIssue	right not to be deprived of life without due process of law ⓘ
country	United States of America ⓘ surface form: United States
court	Supreme Court of the United States ⓘ
decisionDate	1945-05-07 ⓘ
decisionType	plurality opinion ⓘ
defendantRole	county sheriff ⓘ local law enforcement officials ⓘ
effect	limited the reach of federal criminal civil rights protections at the time ⓘ made federal prosecutions of state and local officials for civil rights violations more difficult ⓘ
fullName	Screws v. United States self-linksurface differs ⓘ surface form: Screws v. United States, 325 U.S. 91 (1945)
historicalContext	decided during the World War II era ⓘ
historicalSignificance	early and influential interpretation of the federal criminal civil rights statute ⓘ shaped later federal prosecutions of police brutality and official misconduct ⓘ
holding	a conviction under the statute is valid only if the jury is instructed that the defendant must have had the purpose to deprive the victim of a constitutional right ⓘ the federal civil rights statute requires proof that the defendant acted with a specific intent to deprive a person of a federal right ⓘ
issue	meaning of the term "willfully" in the federal civil rights criminal statute ⓘ scope of federal criminal liability for state officials who violate constitutional rights ⓘ
jurisdiction	federal ⓘ
legalArea	constitutional law ⓘ criminal procedure ⓘ federal civil rights law ⓘ
locationOfIncident	Baker County, Georgia NERFINISHED ⓘ
majorityOpinionBy	William O. Douglas ⓘ surface form: Justice William O. Douglas
proceduralPosture	review of federal criminal convictions of local officials under the civil rights statute ⓘ
raceContext	involved racially motivated violence against a Black victim ⓘ
relatedCase	United States v. Guest ⓘ United States v. Price ⓘ
relatedConcept	federal enforcement of civil rights against state actors ⓘ specific intent in criminal law ⓘ
remedy	convictions were vacated and the case was remanded for further proceedings ⓘ
standardCharacterization	narrow interpretation of willfulness requirement ⓘ
standardEstablished	willful intent standard under 18 U.S.C. § 242 ⓘ
stateOfIncident	Georgia ⓘ
statuteInterpreted	18 U.S.C. § 242 ⓘ 18 U.S.C. § 52 (1940 ed.) ⓘ
subsequentCodification	18 U.S.C. § 242 is the modern codification of the statute interpreted in the case ⓘ
term	1944 Term of the Supreme Court of the United States ⓘ
victimDescription	Black man beaten to death by local law enforcement officers ⓘ
voteSplit	plurality with multiple concurrences and dissents ⓘ
yearDecided	1945 ⓘ

How these facts were elicited

Referenced by (3)

Full triples — surface form annotated when it differs from this entity's canonical label.

United States Supreme Court cases of the Stone Court → includesCase → Screws v. United States ⓘ

Screws v. United States → fullName → Screws v. United States self-linksurface differs ⓘ

this entity surface form: Screws v. United States, 325 U.S. 91 (1945)

Monroe v. Pape, 365 U.S. 167 (1961) → relatedCase → Screws v. United States ⓘ