Robinson v. California Case Brief

Facts of the case

A jury found defendant guilty under a California statute that criminalized being addicted to narcotics. His conviction was affirmed on appeal. Defendant sought further review from the United States Supreme Court.

Why is the case important?

A California statute makes it a criminal offense for a person to be addicted to the use of narcotics. Appellant, Robinson was found guilty of the offense.

Question

Did the California state law violate the Constitution?

ANSWER

No. The statute makes the “status” of being addicted to narcotics illegal “at any time before he reforms.” Since addiction can properly be termed a disease, the United States Supreme Court (Supreme Court) likens this statute to making it a crime to be mentally ill or to have a venereal disease. Certainly, criminalizing having the disease would be universally thought to be cruel and unusual punishment.

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 .

  • Advocates: –
  • Appellant: Robinson
  • Appellee: California
  • DECIDED BY:Warren Court
  • Location: Place of arrest
Citation: 370 US 660 (1962)
Argued: Apr 17, 1962
Decided: Jun 25, 1962
Robinson v. California Case Brief