Robinson v. California
Encyclopedia
Robinson v. California, 370 U.S. 660
(1962), was a case in which the Supreme Court of the United States
held that the use of civil imprisonment as punishment solely for the misdemeanor crime of addiction to a controlled substance
was a violation of the Eighth Amendment
's protection against cruel and unusual punishment.
The Court ruled that the California law violated the cruel and unusual punishment
clause as narcotics addiction "is apparently an illness", and California was attempting to punish people based on being in this state of illness, rather than for any specific act. A person guilty under this law, the Court noted, might never have taken any narcotics at all while in California, nor engaged in any destructive behavior.
Robinson was stopped by a police officer after he noticed apparent "tracks" on Robinson's arms. The officer claimed Robinson admitted that he had occasionally injected narcotics, though Robinson denied this and also denied being an addict. The police arrested him under a California law making it a misdemeanor to "be addicted to the use of narcotics"; Robinson was convicted, and sentenced to 90 days' imprisonment.
The Court wrote that though a 90-day prison sentence itself was neither cruel nor unusual in the abstract, the sentence was out of proportion to the "offense". By way of analogy, it wrote, "Even one day in prison would be a cruel and unusual punishment for the 'crime' of having a common cold."
With this ruling the court established that in order for one to be charged with a criminal act, it was necessary for one to commit an "act." The court invalidated a law which made the state of being addicted a crime. Furthermore, it argued that the invalidated law would have Robinson declared a criminal and sent to jail despite the fact that he may have never actually used drugs in the state of California.
By June 25, 1962, the day the Court handed down this decision, Lawrence Robinson had already been dead for more than ten months. In fact, he was dead before his appeal papers were filed in the Supreme Court. The California Attorney General's office discovered this fact upon remand and notified the Court, since this arguably mooted the case long before its decision. The Court, however, did not vacate the Robinson decision as moot. See Robinson v. California, 371 U.S. 905 (1961) (order denying petition for rehearing and abatement of judgment with dissent).
In 1968, this case was used to challenge a Texas law against public intoxication
, but in the majority opinion by Justice Thurgood Marshall
the court upheld the law. In Powell v. Texas
, however, the court made the distinction between a public behavior and a physical condition and did not overrule Robinson.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1962), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that the use of civil imprisonment as punishment solely for the misdemeanor crime of addiction to a controlled substance
Controlled substance
A controlled substance is generally a drug or chemical whose manufacture, possession, or use are regulated by a government. This may include illegal drugs and prescription medications ....
was a violation of the Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
's protection against cruel and unusual punishment.
The Court ruled that the California law violated the cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
clause as narcotics addiction "is apparently an illness", and California was attempting to punish people based on being in this state of illness, rather than for any specific act. A person guilty under this law, the Court noted, might never have taken any narcotics at all while in California, nor engaged in any destructive behavior.
Robinson was stopped by a police officer after he noticed apparent "tracks" on Robinson's arms. The officer claimed Robinson admitted that he had occasionally injected narcotics, though Robinson denied this and also denied being an addict. The police arrested him under a California law making it a misdemeanor to "be addicted to the use of narcotics"; Robinson was convicted, and sentenced to 90 days' imprisonment.
The Court wrote that though a 90-day prison sentence itself was neither cruel nor unusual in the abstract, the sentence was out of proportion to the "offense". By way of analogy, it wrote, "Even one day in prison would be a cruel and unusual punishment for the 'crime' of having a common cold."
With this ruling the court established that in order for one to be charged with a criminal act, it was necessary for one to commit an "act." The court invalidated a law which made the state of being addicted a crime. Furthermore, it argued that the invalidated law would have Robinson declared a criminal and sent to jail despite the fact that he may have never actually used drugs in the state of California.
By June 25, 1962, the day the Court handed down this decision, Lawrence Robinson had already been dead for more than ten months. In fact, he was dead before his appeal papers were filed in the Supreme Court. The California Attorney General's office discovered this fact upon remand and notified the Court, since this arguably mooted the case long before its decision. The Court, however, did not vacate the Robinson decision as moot. See Robinson v. California, 371 U.S. 905 (1961) (order denying petition for rehearing and abatement of judgment with dissent).
In 1968, this case was used to challenge a Texas law against public intoxication
Public intoxication
Public intoxication, also known as "drunk and disorderly", is a summary offense in many countries rated to public cases or displays of drunkenness...
, but in the majority opinion by Justice Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
the court upheld the law. In Powell v. Texas
Powell v. Texas
Powell v. Texas, 392 U.S. 514 , was a United States Supreme Court case which ruled that a Texas statute criminalizing public intoxication did not violate the Eighth Amendment protection against cruel and unusual punishment. It was a 5-4 decision, and the majority opinion was by Justice Thurgood...
, however, the court made the distinction between a public behavior and a physical condition and did not overrule Robinson.