Robinson v. California (West's Encyclopedia of American Law)
In Robinson v. California, 370 U.S. 660, 82 S. Ct. 1417, 8 L. Ed. 2d 758 (1962), the U.S. Supreme Court made two landmark rulings on the scope and meaning of the CRUEL AND UNUSUAL PUNISHMENTS CLAUSE of the EIGHTH AMENDMENT to the U.S. Constitution.
The Eighth Amendment guarantees that "Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted." At issue in Robinson v. California was the constitutionality of a California CRIMINAL LAW that made being a narcotics addict a crime. To reach this issue, however, the Court first broke new ground and ruled that the Eighth Amendment applied to the states through the DUE PROCESS CLAUSE of the FOURTEENTH AMENDMENT.
Lawrence Robinson was stopped on a city street by a Los Angeles police officer, who had noticed that Robinson's arms were scabbed, discolored, and filled with needle marks. The officer arrested Robinson, who was sent to the Los Angeles central jail. The next day his arms were again examined, this time by a member of the narcotics division of the police department. Based on his examination, the officer concluded the marks and discoloration were the result of the injection of unsterilized hypodermic needles into Robinson's arms. Both police officers claimed that Robinson admitted he had occasionally used narcotics.
Robinson was charged...
(The entire section is 1248 words.)
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Robinson v. California (Great American Court Cases)
Legal Citation: 370 U.S. 660 (1962)
State of California
That the state violated his Eighth and Fourteenth Amendment rights, which protect him from cruel and unusual punishment, because the state of California sentenced him to 90 days in jail for having a drug addiction.
Chief Lawyer for Petitioner
S. Carter McMorris
Chief Lawyer for Respondent
William E. Doran
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, John Marshall Harlan II, Potter Stewart (writing for the Court), Earl Warren
Tom C. Clark, Byron R. White (Felix Frankfurter did not participate)
Date of Decision
25 June 1962
The Court decided to reverse the lower courts' rulings, holding that the sentence violated Robinson's Eighth and Fourteenth Amendment rights to be free from cruel and unusual punishment. The Court reasoned that Robinson's sentence was like imprisoning people for having a mental illness,...
(The entire section is 1643 words.)
Robinson v. California (Supreme Court Drama)
Appellant: Lawrence Robinson
Appellee: State of California
Appellant's Claim: That convicting him for having a drug addiction was cruel and unusual punishment.
Chief Lawyer for Appellant: Samuel Carter McMorris
Chief Lawyer for Appellee: William E. Doran
Justices for the Court: Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, John Marshall Harlan II, Potter Stewart, Earl Warren
Justices Dissenting: Tom C. Clark, Byron R. White (Felix Frankfurter did not participate)
Date of Decision: June 25, 1962
Decision: The Supreme Court reversed Robinson's conviction.
Significance: With Robinson, the Supreme Court said it is cruel and unusual to convict someone for having an illness, such as drug addiction. Robinson helped eliminate status crimes such as vagrancy and homelessness.
Lawrence Robinson was on the streets of Los Angeles one evening when Officer Brown confronted him. Although Robinson was not doing anything wrong, Officer Brown questioned and searched Robinson for evidence of a crime. Brown found needle marks, scar tissue, and discoloration on Robinson's arms. Under questioning, Robinson admitted that he occasionally used illegal drugs. Officer Brown arrested Robinson and took him to the Central Jail in Los Angeles.
The next morning, Officer Lindquist examined Robinson's arms, both in person and in photographs taken the night before. Based on ten years of experience in the Narcotics Division of the Los Angeles Police Department, Officer Lindquist concluded that Robinson was injecting illegal drugs into his arms. According to Lindquist, Robinson admitted this under questioning.
Despite the marks on Robinson's arms, there was no evidence that he was under the influence of illegal drugs or having withdrawal symptoms when he was arrested. California, however, had a law that made it a crime to be addicted to drugs. People convicted under the law got a minimum of ninety days in jail. California charged Robinson with being a drug addict.
At his trial, Robinson said the marks on his arms were an allergy condition he got from shots in the military. Two witnesses for Robinson said the same thing. Robinson denied that he ever used or admitted to using illegal drugs. Officers Brown and Lindquist, however, testified to what they saw on Robinson's arms. The judge instructed the jury that even if there was no evidence that Robinson had used drugs in California, it could convict Robinson for being addicted to drugs while in California. The court said the law made the "condition or status" of drug addiction a crime.
The jury convicted Robinson, so he appealed to the Appellate Department of the Los Angeles County Superior Court. When that court ruled against him too, Robinson appealed to the U.S. Supreme Court.
Cruel and Unusual Punishment
With a 6 decision, the Supreme Court reversed Robinson's conviction. Writing for the Court, Justice Potter Stewart said drug addiction is an illness, not a crime. Punishing someone for an illness violates the Eighth Amendment of the U.S. Constitution, which bans cruel and unusual punishments.
Justice Stewart said states can fight against America's serious drug problem by making it illegal to manufacture, sell, buy, use, or possess illegal drugs. States also may protect their citizens from criminal activity by drug addicts by requiring addicts to get medical treatment.
California's law was different. It was meant to punish drug addicts, not cure them. Justice Stewart said punishing someone for having a drug addiction is like punishing someone for having a mental illness, leprosy, venereal disease, or the common cold. "Even one day in prison would be a cruel and unusual punishment for the 'crime' of having a common cold."
Losing the War on Drugs
Justices Tom C. Clark and Byron R. White dissented, which means they disagreed with the Court's decision. In a dissenting opinion, Justice Clark said California's law was not designed to punish people for drug addiction. It was designed to put them in jail for at least 90 days to help them break the addiction.
In addition, Justice Clark said there is no difference between a person who uses drugs and a person who is addicted to drugs. Both are dangerous to society because drug use leads to health problems and criminal behavior. Convicting someone for a drug addiction is the same as convicting an alcoholic for public drunkenness. They are not status crimes, they are crimes that endanger societal health and welfare. Justice Clark said California should be allowed to protect people from such dangers.
Robinson could have been used to eliminate all crimes resulting from a person's voluntary use of drugs and alcohol. In Powell v. Texas (1968), however, the Supreme Court said addiction to alcohol cannot be used as a defense the crime of public drunkenness. Instead, Robinson has been used to strike down other types of status crimes, such as vagrancy and homelessness.
Suggestions for further reading
Bernards, Neal. The War on Drugs: Examining Cause and Effect Relationships. San Diego: Greenhaven Press, 1991.
Brennan, Michael. "A Case for Discretion." Newsweek, November 13, 1995.
Gottfried, Ted. Should Drugs Be Legalized? Twenty First Century Books, 2000.
Hansen, Mark. "Mandatories Going, Going . . . Gone." ABA J ournal, April 1999.
Johnson, Joan. America's War on Drugs. New York: Franklin Watts, 1990.
Kronenwetter, Michael. Drugs in America: The Users, the Suppliers, the War on Drugs. Englewood Cliffs: Messner, 1990.
Marks, Alexandra. "Rolling Back Stiff Drug Sentences." Christian Science Monitor, December 8, 1998.
Powell, Jillian. Drug Trafficking. Copper Beach Books, 1997.
Santamaria, Peggy. Drugs and Politics. Rosen Publishing Group, 1994.
Stefoff, Rebecca. The Drug Enforcement Administration. New York: Chelsea House, 1989.
Terkel, Susan Neiburg. Should Drugs Be Legalized? New York: Franklin Watts, 1990.
Thompson, Stephen P., ed. The War on Drugs: Opposing Viewpoints. San Diego: Greenhaven Press, 1998.
Wier, William. In the Shadow of the Dope Fiend: America's War on Drugs. Archon, 1997.