In the 1944 case Screws et al. v. United States, Sheriff Claude Screws and two deputies were charged with violating a federal law that made it illegal to deprive someone of their civil rights under color of any state law. The charges stemmed from an incident in which they arrested Robert Hall, an African American man, then brutally beat him to death while he was handcuffed. The defendants argued that they had not violated the statute because they did not act "willfully," as required by the law; rather, they claimed their actions were part of a lawful arrest gone awry due to Hall's resistance. The Supreme Court ruled in favor of Screws and his deputies on technical grounds: It held that specific intent must be proven—that is, prosecutors needed to show that the officers intended specifically to deny Hall his constitutional rights—in order for them to be found guilty under this particular statute. This decision set a high bar for future prosecutions under this federal civil rights law.

The dissenting opinion in the Screws et al. v. United States case argued that the majority's interpretation of Section 20 of the Criminal Code was too broad and vague, potentially leading to misuse or misinterpretation by law enforcement officials. The dissenters believed that this section should only apply when there is a clear intent to deprive someone of their constitutional rights, not just when an official acts wrongly or makes a mistake. They also expressed concern about federal overreach into state matters, arguing that it could undermine states' ability to manage their own affairs effectively and independently. Furthermore, they contended that such broad interpretations could lead to potential abuses of power by federal authorities against local officials who may be acting within their jurisdiction but contrary to federal preferences.