Robinson v. California
370 U.S. 660 (1962)

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U.S. Supreme Court

Robinson v. California, 370 U.S. 660 (1962)

Robinson v. California

No. 554

Argued April 17, 1962

Decided June 25, 1962

370 U.S. 660

Syllabus

A California statute makes it a misdemeanor punishable by imprisonment for any person to "be addicted to the use of narcotics," and, in sustaining petitioner's conviction thereunder, the California courts construed the statute as making the "status" of narcotic addiction a criminal offense for which the offender may be prosecuted "at any time before he reforms," even though he has never used or possessed any narcotics within the State and has not been guilty of any antisocial behavior there.

Held: As so construed and applied, the statute inflicts a cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. Pp. 370 U. S. 660-668.

Reversed.

Primary Holding
It is unconstitutional under the Eighth Amendment to criminalize drug addiction because it is a disease, status, or condition rather than a specific act.
Facts
Robinson admitted to occasional drug use, and the police found track marks on him. He was convicted of violating a California statute that criminalized people who were addicted to narcotics.

Opinions

Majority

  • Potter Stewart (Author)
  • Hugo Lafayette Black
  • William Joseph Brennan, Jr.
  • Earl Warren

While the possession or distribution of illegal drugs may be punished as a crime, the mere status of addiction may not be punished if it is not connected to a concrete instance of use. In some instances, like other illnesses, drug addiction may be contracted involuntarily. This makes any imprisonment imposed on these grounds alone a violation of the Eighth Amendment's prohibition of cruel and unusual punishment.

Dissent

  • Byron Raymond White (Author)

A more appropriate interpretation of the law would be that it prohibits the habitual or regular use of drugs immediately before the defendant's arrest.

Concurrence

  • John Marshall Harlan II (Author)

The desire to commit a criminal act and a heightened propensity for doing so do not amount to actually committing the act.

Dissent

  • Tom C. Clark (Author)

Recused

  • Felix Frankfurter (Author)

Concurrence

  • William Orville Douglas (Author)

Case Commentary

This decision showed that a status or condition may not be criminalized. However, an equally persuasive justification comes from the Harlan concurrence, which states that involuntary acts cannot be punished. There is also no basis for punishing someone for the future potential of criminal conduct, since the criminal justice system is focused on past acts.

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