Powell v. Texas Case Brief

Why is the case important?

Appellant was arrested and charged with public intoxication. The trial judge ruled as a matter of law that chronic alcoholism was not a defense to the charge. Appellant was found guilty and fined fifty dollars.

Facts of the case

Police arrested Leroy Powell for public intoxication. He was tried, convicted, and fined $20 in the Corporation Court of Austin Texas. On appeal, Powell argued that criminal punishment for public intoxication is cruel and unusual punishment in violation of the Eighth Amendment, because he had chronic alcoholism. Under this theory, he appeared in public drunk as a compulsive symptom of the disease, not his own choice. The County court of Travis County held that alcoholism is not a defense to the charge and affirmed the conviction.

Question

Does chronic alcoholism qualify as a disease such that it is a defense to the charge of public intoxication?

Answer

No and No. Conviction upheld.
The dissent’s position that a person cannot be punished if the condition essential to constitute the crime is part of the pattern of his disease, predicated upon a compulsion of the disease, goes much too far on the basis of too little knowledge. The record in this case is inadequate to permit such a ruling. There is no information about the circumstances surrounding the incident leading to the arrest and there is no agreement among members of the medical profession about what it means to say alcoholism is a disease.

Conclusion

“The court held that there was no agreement among members of the medical community that the condition of chronic alcoholism was a disease. The district court’s finding that defendant was afflicted with the disease of chronic alcoholism was problematic because the district court failed to articulate what symptoms would be required to make out a constitutional defense, should one be recognized. Defendant’s conviction did not warrant reversal under the Cruel and Unusual Punishment Clause because the district court did not seek to punish a mere status

  • instead, it imposed a criminal sanction for public behavior which might create health and safety issues.”
    • Case Brief: 1968
    • Appellant: Leroy Powell
    • Appellee: Texas
    • Decided by: Warren Court

    Citation: 392 US 514 (1968)
    Argued: Mar 7, 1968
    Decided: Jun 17, 1968
    Granted Oct 9, 1967