Robinson v. California
Robinson v. California is a landmark Supreme Court case from 1962 that addressed the legality of criminalizing drug addiction. The Court ruled in a 7-2 decision that a California law, which made it a crime to be a drug addict without requiring evidence of drug possession or use, was unconstitutional. The majority opinion, penned by Justice Potter Stewart, characterized addiction as a medical condition rather than a criminal offense, emphasizing that punishing someone for an illness constituted cruel and unusual punishment under the Eighth Amendment. Dissenting Justices argued that detention could be a means of addressing and controlling substance addiction. This decision significantly influenced the legal landscape regarding substance abuse and the justice system's approach to addiction. However, its breadth was later limited by the Powell v. Texas case in 1968, which allowed for the punishment of chronic alcohol addiction. Robinson v. California remains an important reference point in discussions about addiction, mental health, and the legal system's responsibilities toward individuals suffering from these issues.
Robinson v. California
Date: June 25, 1962
Citation: 370 U.S. 660
Issues: Eighth Amendment; cruel and unusual punishment
Significance: The Supreme Court applied the Eighth Amendment’s cruel and unusual punishment clause to the states through incorporation via the Fourteenth Amendment.
Justice Potter Stewart wrote the opinion for the 7-2 majority, striking down a California law that made it a crime to be a drug addict without any proof that the defendant bought, used, or possessed any drugs. Under the statute, the state could convict merely by showing tangential proof such as needle marks on the defendant’s arms. The Supreme Court reasoned that addiction was an illness rather than a crime and that even ninety days in jail amounted to cruel and unusual punishment. Justices Tom C. Clark and Byron R. White dissented, asserting that detention could be used to attempt to control addiction to narcotics. The scope of the decision was substantially narrowed six years later when a new majority found that chronic alcohol addiction could be punished with jail time in Powell v. Texas (1968).
