Robinson v. California (1961)
- Docket
- 554
- Decided
- 1961-01-01
Summary
Question: Was defendant’s conviction for addiction to narcotics under the California law cruel and unusual punishment prohibited by the Eighth Amendment? Conclusion: In a 6-2 decision authored by Justice Potter Stewart, the Court held that laws imprisoning persons afflicted with the "illness" of narcotic addiction inflicted cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The Court likened the law to one making it a criminal offense "to be mentally ill, or a leper, or to be afflicted with a venereal disease," and argued that the state could not punish persons merely because of their "status" of addiction. The Court noted that the law was not aimed at the purchase, sale, or possession of illegal drugs. While joining the Court's opinion, Justice Douglas, in a separate opinion, elaborated the reasons why the statute was regarded as imposing a cruel and unusual punishment. Justice Harlan concurred on the ground that the trial court's instruction permitted the jury to find defendant guilty on no more proof than that he was present in California while he was addicted to narcotics, and hence authorized punishment for a bare desire to commit a criminal act. Justice Clark dissented, primarily on the ground that, properly construed, the statute provided a treatment rather than a punishment. Justice White also dissented, expressing the view that it was within the power of the state to confine the defendant by criminal proceedings for the use of narcotics or for regular use amounting to habitual use.