Law School Case Brief
Robinson v. California - 370 U.S. 660, 82 S. Ct. 1417 (1962)
A state law that imprisons as a criminal a person afflicted with a narcotic addiction, even though he has never touched any narcotic drug within the state or been guilty of any irregular behavior there, inflicts a cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments.
A jury in California state court found defendant Robinson guilty under Cal. Health & Safety Code § 11721 for being addicted to the use of narcotics, a conviction that was affirmed on appeal. Trial included a police officer's testimony that defendant had scar tissue and discoloration on the inside of his arm, as well as needle marks and a scab below the crook of the elbow, which the officer believed was the result of injections by hypodermic needles. The officer also testified that defendant admitted to the occasional use of narcotics. At the time of his arrest, defendant was not engaged in any illegal conduct, and there was no proof that he had actually used narcotics within California. Defendant sought further review from the Supreme Court of United States.
Was Cal. Health & Safety Code § 11721 violative of the Fourteenth Amendment?
The Supreme Court of the United States found § 11721 to be unconstitutional and in violation of U.S. Const. amend. XIV for inflicting cruel and unusual punishment. The Court concluded that § 11721 made the status of being addicted to the use of narcotics a criminal offense, whether or not an accused ever used or possessed narcotics within California or had been guilty of any antisocial behavior there.
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