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Robinson v. California

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 did not 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 host of valid methods. Writing for the majority, Justice Stewart urged that despite the states' independence in deciding on appropriate methods to control the spread and addiction to narcotics, the states had to respect the rights provided by the Constitution made applicable to the states through the Fourteenth Amendment.

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 them for 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 and possess narcotics in order to use them repeatedly or to be an addict.

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