Robinson v. California

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370 U.S. 660 (1962), argued 17 Apr. 1962, decided 25 June 1962 by vote of 7 to 2; Stewart for the Court, White and Clark in dissent. In Robinson v. California a California law making it a crime to be a drug addict was held to be unconstitutional as cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The statute did not require proof that the defendant bought or used drugs or had any in his or her possession. The mere status of being an addict, which could be established, for example, by needle marks on the offender's arm, was sufficient. The U.S. Supreme Court held that addiction is an illness rather than a crime and thought that ninety days in jail for being ill constituted cruel and unusual punishment. Justices Byron White and Tom Clark argued in dissent that detention was a feature of “a comprehensive and enlightened program for the control of narcotism” (p. 679).

The Robinson decision was not followed in a 1968 ruling, Powell v. Texas, where the Court, by a 5-to-4 vote, rejected the contention that criminal conviction for chronic alcoholism was cruel and unusual. The Court majority thought that knowledge about alcoholism and the record in this case were inadequate for a wide-ranging new constitutional principle. Justice Abe Fortas, writing for the minority in the Powell case, insisted that the Robinson rule should be followed, and that “criminal penalties may not be inflicted upon a person for being in a condition he is powerless to change” (p. 533).

Controversy has continued concerning whether addiction-related conduct is involuntary and entitled to be regarded as a disease, but the Robinson case did establish that the Cruel and Unusual Punishment Clause of the Eighth Amendment applies to the states in appropriate cases by reason of the Due Process Clause of the Fourteenth Amendment.

C. Herman Pritchett

Subjects: Law.

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