State and Federal Authority in Screws v. United States Essay

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State and Federal Authority in Screws v. United States

Outside the courthouse in Newton, Georgia, in the early hours of January 30, 1943, Robert “Bobby” Hall was beaten unconscious by M. Claude Screws, Frank Edward Jones, and Jim Bob Kelley[1] while in their custody for the alleged theft of a tire;[2] Screws, Jones and Kelley were, respectively, Baker county sheriff, night policeman, and a civilian deputized specifically for the arrest.[3] Without ever recovering consciousness, Hall died as a result of a fractured skull shortly after his arrival at an Albany hospital that morning.[4] The NAACP and FBI investigated Hall’s death in the following months and federal charges were brought against Screws, Jones, and Kelley for violation
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In the Court’s highly fragmented decision, the justices attempted to define a proper balance of and boundary between federal and state authority: by arguing that state action constituted only those acts sanctioned by the state’s laws and by dismissing Section 20 for vagueness, the major block of dissenters suggested that the risk posed to state autonomy by federal intervention was too great; by recognizing the defendants’ actions as those perpetrated “under color of law” and by creating a “willful” test for acts under Section 20, the majority Opinion affirmed the federal government’s interest in protecting the rights of citizens from abuse by state authority, but provided it with a tenuous means for defending those liberties.

Phoebe Putney Memorial Hospital in Albany, Georgia, received a call to collect Bobby Hall from the Newton jail at approximately 2:30 a.m. on January 30, 1943.[6] When the ambulance drivers, Manley Poteat and Henry Neal, entered the jail cell where Hall lay dying, they saw blood on the floor around his unconscious body.[7] As already stated, Hall died shortly after his arrival at the hospital. It did not take long for suspicion to arise regarding the circumstances of his death. A post mortem examination of Hall’s body revealed that he was “stripped of clothing and showing many contusions and bruises, covered with dirt and blood.” The back of his skull was “beaten soft.”[8] Hall’s father, Willie Hall, noted that there

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