Robinson v. California

Petitioner
Lawrence Robinson
Respondent
State of California
Petitioner's Claim
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
Justices Dissenting
Tom C. Clark, Byron R. White (Felix Frankfurter did not participate)
Place
Washington, D.C.
Date of Decision
25 June 1962
Decision
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 sentencewas like imprisoning people for having a mental illness, a venereal disease,or leprosy and maintained that drug laws should strive to prevent the sale, use, and possession of illegal drugs, but not punish people with the status ofhaving a drug addiction.
Significance
Initially with this case, the U.S. Supreme Court took a strong stand on whatconstituted a crime and what did not. Here the Court in effect said that states cannot punish people for behavior stemming from a condition beyond their control. However, after subsequent decisions such as Powell v. Texas (1968) the Court moved away from this position, reducing the Robinson decision to simply a ban that prohibits states from punishing people for havinga status or condition. Nonetheless, the decision helped eliminate status-based crimes such as vagrancy and homelessness.
Under California law, the state could convict people for having a narcotic addiction and a jury in the Municipal Court of Los Angeles convicted Lawrence Robinson of having an illegal drug addiction in 1962. The evidence against Robinson came from reports by two Los Angeles police officers, including an unorthodox search of him on a street in Los Angeles by one of the officers. The first police officer greeted Robinson and proceeded to question and search himwithout any provocation or apparent suspicion. During the course of this incident, the police officer examined Robinson's arm and noticed scars and discoloration on the inside of his arm as well as what the officer took to be multiple needle marks. The officer also testified that Robinson admitted he usednarcotics on occasion. He eventually arrested him and held him in jail.
The second police officer testified that he also observed the scabs and discoloration on Robinson's arm the morning after his arrest. In addition, this officer identified photographs taken of Robinson's arm, which showed the scabsand discoloration. As a ten-year veteran of the Narcotics Division of the LosAngeles Police Department, this officer argued that "these marks and the discoloration were the result of the injection of hypodermic needles into the tissue of the vein that was not sterile." Furthermore, he told the jury that Robinson was not intoxicated by narcotics when he examined him and that he didnot seem to be experiencing any withdraw symptoms.
However, Robinson testified that he had not admitted to using narcotics to the police and argued that he never used or was addicted to any drugs. He attributed the scabs and discoloration to an allergic condition he got while in the military. Moreover, two witnesses confirmed Robinson's testimony.
The judge in the trial explained to the jury that California law considered it a misdemeanor to use narcotics or to be addicted to the use of narcotics. The law distinguished between the act of using narcotics and the status or condition of being addicted to the use of narcotics. The state viewed a charge of use as a one time offense, but a charge of addiction as a continuous offense until the user reformed. The judge also instructed the jury that it could convict Robinson under a general verdict, if it determined that Robinson either had the condition of being addicted to narcotics or he used narcotics whilein Los Angeles. The jury ultimately convicted Robinson under the general verdict and he was sentenced to 90 days in prison.
Robinson appealed the decision to the Los Angeles County Superior Court, which although it had some reservations about the constitutionality of narcoticsaddiction as crime, nonetheless upheld Robinson's conviction. The Los AngelesCounty Superior Court based its decision on two previous state cases that questioned the constitutionality of the law where the court had also upheld it.
Cruel and Unusual Punishment
Robinson then petitioned the U.S. Supreme Court, arguing that the law violated his Eighth and Fourteenth Amendment rights, because it punished him for having a drug addiction. In a 6-2 decision, the Court made it clear that it didnot want to interfere with the regulation of illegal drugs in the states, because it felt the states could control the traffic of illegal drugs by a hostof valid methods. Writing for the majority, Justice Stewart urged that despite the states' independence in deciding on appropriate methods to control thespread and addiction to narcotics, the states had to respect the rights provided by the Constitution made applicable to the states through the FourteenthAmendment.
The majority reasoned that because the court could have convicted Robinson even if it did not have evidence that he used narcotics while in Los Angeles, the law could punish him for merely having the addiction. Since the jury convicted him under the general verdict, which did not separate the use from the addiction, the majority believed that the jury could have found Robinson guilty for having the signs of a drug addiction alone. The Court argued that the law violated Robinson's rights, because it could convict him for having the status or condition of being a drug addict, and not for using, possessing, selling, or manufacturing drugs. Furthermore, the majority contended that punishing people for simply having a drug addiction was tantamount to punishing themfor having a mental illness or a disease.
However, Justices Clark and White dissented, maintaining respectively that the California law actually provided treatment, not punishment, under the appropriate interpretation and that the states have the power to imprison people for illegal drug use and addiction through the criminal justice system. Justice Clark felt that in the proper context the law did not punish people for drug addictions, because the state felt the confinement was a time for the addict to break the addiction. Moreover, he argued that the state has another statute for more serious addicts where sentences range from three months to two years in a state hospital. Justice White, on the other hand, argued that Robinson's sentence was not a punishment for his status, but for being a regular,habitual user of narcotics right before his arrest, which California law prohibits. Justice White supported the conviction because Robinson had to use andpossess narcotics in order to use them repeatedly or to be an addict.
The Consequences
This decision began to pave the way for the elimination of status based crimes and reduced prosecution of people for conduct caused by a condition out oftheir control, according to Ronald J. Allen in Journal of Criminal Law andCriminology. However, Powell v. Texas put an end to the latter kind of interpretation, leaving the Robinson case with only one common reading: the ban on the punishment for and the criminalization of a status orcondition. In this case, the Court found that even though chronic alcoholismis a disease that destroys the will power of the afflicted, alcoholism cannotbe used as a defense against a charge, because the compulsion to drink is not completely overpowering. Nonetheless, this decision rendered laws that punished vagrants and homeless people invalid in the 1970s, but as homelessness escalated in the 1980s and 1990s some states tried to bypass the Robinson ruling by outlawing activities that accompany homelessness such as sleeping in doorways and public places.
Related Cases

• Jacobson v. Massachusetts, 197 U.S. 11 (1905).
  
• Whipple v. Martinson, 256 U.S. 41 (1921).
  
• Powell v. Texas, 392 U.S. 514 (1968).

The Anti-Drug Abuse Act of 1986
The Anti-Drug Abuse Act of 1986 would, during the 1990s, attract controversydue to the wide disparity between the penalties it placed on the distributionof crack cocaine as compared with those for powder cocaine. Because crack isless expensive than cocaine, and thus more popular among inner-city youths,critics charged that the establishment of the same penalty for selling one gram of crack as for selling 100 grams of cocaine was inherently racist.
At the center of the act were two tiers of mandatory prison terms for first-time drug traffickers. For what Congress called "serious offenders," or "the managers of the retail-level traffic," there was a mandatory minimum of five years. For "major traffickers," that is "the manufacturers or the heads of organizations who are responsible for creating and delivering very large quantities," the mandatory minimum was ten years. Differentiation between the levelsof offense was based on quantity and type of drug being sold.
Though the act clearly seems to be imbalanced with regard to the penalties for crack and cocaine, there is little reason to believe that its sponsors weremotivated by racism. Rather, the act happened to come to Congress's attention at a high point of national concern over drugs in general, crack in particular.
Sources
"Report on Cocaine and Federal Sentencing Policy." United States Sentencing Commission, http://www.ussc.gov.