Robinson v. California
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|Robinson v. California|
|Argued April 17, 1962
Decided June 25, 1962
|Full case name||Robinson v. California|
|Citations||370 U.S. 660 (more)|
|Prior history||Appeal from the Appellate Department, Superior Court of California, Los Angeles County, 370 U.S. 660.|
|Punishing a person for a medical condition is a violation of the Eighth Amendment ban on cruel and unusual punishment.|
|Majority||Stewart, joined by Warren, Black, Douglas, Harlan, Brennan|
|Frankfurter took no part in the consideration or decision of the case.|
Robinson v. California, 370 U.S. 660 (1962), is the United States Supreme Court case striking down a California law that criminalized people for being addicted to narcotics. Until the Robinson opinion, all Eighth Amendment decisions addressed whether the method of punishment was cruel and unusual, or whether a punishment was too excessive in light of the nature of the crime, so as to make the severity of the sentence cruel and unusual. Robinson was the first case to place substantive limits on who or what the government can criminalize. Following the Robinson decision, the Court invalidated a Texas law criminalizing homosexual acts through anti-sodomy laws under Lawrence v. Texas, 539 U.S. 558 (2003), and upheld a law criminalizing public drunkenness under Powell v. Texas, 392 U.S. 514, 517 (1968).
Robinson was stopped by a police officer who observed "tracks" on Robinson's arms from heroin use. The officer claimed Robinson admitted that he had occasionally injected narcotics, though Robinson denied admitting this, and also denied being an addict. The police arrested him under California law making it a misdemeanor to "be addicted to the use of narcotics"; Robinson was convicted, and sentenced to 90 days' imprisonment.
While the Robinson Court held that a law criminalizing drug addiction is a violation of the Eighth Amendment's protection against cruel and unusual punishment, the reasoning underlying the constitutional violation is multi-layered, and differed among the Justices. First, Justice Stewart's opinion (joined by Justices Black, Warren, and Brennan,) in combination with Douglas's concurring opinion, recognized that drug addiction is a disease, and that people cannot be constitutionally punished for having a disease. Justice Stewart wrote that even "one day in prison for the 'crime' of having a common cold," would be cruel and unusual. Second, Justice Stewart's opinion, in combination with Justice Harlan's concurring opinion, held that it is unconstitutional to criminalize behavior in the absence of an act, or actus reus. Justice Stewart's opinion focused on the unconstitutionality of punishing a mere status or condition, while Justice Harlan's concurring opinion focused on the unconstitutionality of punishing a "bare desire.".
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).
- Robinson v. CA, 370 U.S. 660; The statute was § 11721 of the California Health and Safety Code. It provided: ‘No person shall use, or be under the influence of, or be addicted to the use of narcotics, excepting when administered by or under the direction of a person licensed by the State to prescribe and administer narcotics.’
- Wilkerson v. State of Utah, 99 U.S. 130, 136 (1878); In re Kemmler, 136 U.S. 436, 447 (1890); Trop v. Dulles, 356 U.S. 86, 101 (1958); For example, in Francis v. Resweber, 329 U.S. 459 (1947), the Court considered whether Louisiana could try a second time to electrocute a convicted murderer, after the first attempt failed because of a defect in the State's electric chair. (The Court held, 5-4, that re-electrocuting the defendant Frances was not cruel and unusual.)
- See Anthony F. Granucci, “Nor Cruel and Unusual Punishments Inflicted”: The Original Meaning, 57 CAL.L.REV. 839 (1969).
- Robinson, 370 U.S. at 667-676
- Robinson, 370 U.S. at 667
- Id. at 664, 678-679
- Id. 666-667
- Id. 678-679
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