Robinson v. California

370 U.S. 660, 82 S. Ct. 1417 (1962)

 

RULE:

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

FACTS:

A California statute made it a misdemeanor punishable by imprisonment for any person to "be addicted to the use of narcotics." A jury found defendant guilty under Cal. Health & Safety Code § 11721 for being addicted to the use of narcotics and the conviction was affirmed on appeal. Defendant sought further review from the United States Supreme Court because 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. The record 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. But at the time of arrest, the defendant was not using or in possession of any narcotics.

ISSUE:

Is the California statute unconstitutional for inflicting cruel and unusual punishment?

ANSWER:

Yes

CONCLUSION:

The Court concluded that § 11721 made the status of being addicted to the use of narcotics a criminal offense, whether or not he ever used or possessed narcotics within California or had been guilty of any antisocial behavior there. The Court found § 11721 to be unconstitutional and in violation of U.S. Const. amend. XIV for inflicting cruel and unusual punishment. A state statute which makes it a criminal offense, punishable by imprisonment for not less than 90 days nor more than one year, to be addicted to the use of narcotics, even though the accused 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 Eight and Fourteenth Amendments.

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