Robinson v. California

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Robinson v. California

Supreme Court of the United States

Argued April 17, 1962
Decided June 25, 1962

Full case name:	Robinson v. California

Citations:	370 U.S. 660
Prior history:	Appeal from the Appellate Department, Superior Court of California, Los Angeles County, 370 U.S. 660.

Holding

Punishing a person for a medical condition is a violation of the Eighth Amendment ban on cruel and unusual punishment.

Court membership

Chief Justice: Earl Warren
Associate Justices: Hugo Black, Felix Frankfurter, William O. Douglas, Tom C. Clark, John Marshall Harlan II, William J. Brennan, Jr., Charles Evans Whittaker, Potter Stewart

Case opinions

Majority by: Stewart
Joined by: Warren, Black, Douglas, Harlan, Brennan, Whittaker
Concurrence by: Douglas
Concurrence by: Harlan
Dissent by: Clark
Dissent by: White

Robinson v. California, 370 U.S. 660 (1962)^[1], 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 "using" or being under the influence of 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." The court invalidated a law which made the state of being addicted a crime. Furthermore, it argued that the invalidated law would have Robinson declared a criminal and sent to jail despite the fact that he may have never actually used drugs in the state of California.

In 1968, this case was used to challenge a Texas law against public intoxication, but in the majority opinion by Justice Thurgood Marshall the court upheld the law. In Powell v. Texas, however, the court made the distinction between a public behavior and a physical condition and did not overrule Robinson.