State and Federal Authority in Screws v. United StatesOutside 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 while in their custody for the alleged theft of a tire; Screws, Jones and Kelley were, respectively, Baker county sheriff, night policeman, and a civilian deputized specifically for the arrest. Without ever recovering consciousness, Hall died as a result of a fractured skull shortly after his arrival at an Albany hospital that morning. The NAACP and FBI investigated Hall’s death in the following months and federal charges were brought against Screws, Jones, and Kelley for violation of Section 20 of the Federal Criminal Code, which stipulates that no person may “under color of any law … willfully” deprive a person of “any rights, privileges, or immunities secured or protected by the Constitution and laws of the United States.” After being found guilty in the lower courts, the defendants brought their case to the Supreme Court on appeal, alleging that they had violated a state rather than federal law and, consequently, could not be held liable under Section 20. The Supreme Court’s central concern in Screws et al. v. United States was to interpret the intent and breadth of Section 20 in order to judge its constitutionality; in doing so, the Court struggled to reach a consensus regarding the definition of state action and the indefinite nature of the rights protected by the statute. Such consensus proved difficult, indeed, as the case was narrowly decided and divided the Court along deep constitutional lines; while a majority of the Court advocated reversal of the lower co…
 Screws et al. v. United States, 325 U.S. 91, 151-152 (1945).
 Ibid., 143.
 Ibid., 111.
 Ibid., 145-146.
 Ibid., 149.
 Memorandum by Mr. Justice Jackson, February 2, 1945, Jackson Papers, 5.
 See Justice Murphy’s dissent, wherein he insists that “it is idle to speculate on other situations that might involve § 20 which are not now before us.” Screws et al. v. United States, 325 U.S. 91, 136 (1945).
 Felix Frankfurter to Chief Justice Stone, November 30, 1944, Harlan Fiske Stone Papers.
 Justice Frank Murphy’s Notes on Screws et al. v. United States, Frank Murphy Papers.
 Screws et al. v. United States, 325 U.S. 91, 139 (1945).
 Memorandum by Mr. Justice Jackson, February 2, 1945, Jackson Papers, 6.
 Harlan Fiske Stone to William O. Douglas, November 25, 1944, Harlan Fiske Stone Papers.