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), 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."
Until the Robinson opinion, all decisions of the Court concerning "cruel and unusual punishment" had addressed either the kind of punishment meted out to the defendant or whether although conventional the punishment was disproportionate to the nature of the offense, as contrasted with whether the defendant's conduct merited punishment at all. 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.) In Weems v. United States, 217 U.S. 349 (1910), the Court held that 15 years of imprisonment in chains and at hard labor was disproportionate to the offense of making false bookkeeping entries. In the Francis case, the Court gave as examples of cruel and unusual punishment, "burning at the stake, crucifixion, [and] breaking on the wheel." After the Robinson decision, courts placed increasing focus on whether it was appropriate to punish given conduct, such as public drunkenness.
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 in Powell v. Texas. The court made the distinction between a public behavior and a physical condition, and thus upheld the law and did not overrule Robinson.
- See Powell v. Texas (unsuccessful 8th amendment challenge); Lawrence v. Texas, 539 U.S. 558 (2003) (overturning state anti-sodomy law).
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