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Robinson v. California

Significance

Initially with this case, the U.S. Supreme Court took a strong stand on what constituted 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 having a 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 him without 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 used narcotics 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 scabs and discoloration. As a ten-year veteran of the Narcotics Division of the Los Angeles 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 did not 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 while in 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 narcotics addiction as crime, nonetheless upheld Robinson's conviction. The Los Angeles County Superior Court based its decision on two previous state cases that questioned the constitutionality of the law where the court had also upheld it.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1954 to 1962Robinson v. California - Decision, Significance, Cruel And Unusual Punishment, The Consequences, The Anti-drug Abuse Act Of 1986