Robinson v. California

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 of their control, according to Ronald J. Allen in Journal of Criminal Law and Criminology. 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 or condition. In this case, the Court found that even though chronic alcoholism is a disease that destroys the will power of the afflicted, alcoholism cannot be 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.