ROBINSON V CALIFORNIA

This is an audio case brief of Robinson v. California, 370 U.S. 660 (1962). The audio brief provides a full case analysis. However a written summary of the case is provided below.

Table of Contents

FACTS

Two Los Angeles police officers provided testimony for Robinson’s conviction.

Officer Brown testified that he examined Robison’s arms one evening on a street in Los Angeles about four months before the trial. He testified further that during the examination, he observed “scar tissue and discoloration on the inside” of the Robinson’s right arm, and “what appeared to be numerous needle marks and a scab. The scab was approximately three inches below the crook of the elbow on Robinson’s left arm. He also testified that when Robinson was questioned, he admitted to the occasional use of narcotics.

The second officer, officer Lindquist testified that he examined Robinson the following morning in the Central Jail in Los Angeles. He stated that he had observed discolorations and scabs on Robinson’s arms. And later identified photographs which had been taken of the Robinson’s arms shortly after his arrest the night before. Based upon more than ten years of experience as a member of the Narcotic Division of the Los Angeles Police Department, the officer gave his opinion that “these marks and the discoloration were the result of the injection of hypodermic needles into the tissue into the vein that was not sterile.” He stated that the scabs were several days old at the time of his examination, and that the appellant was neither under the influence of narcotics nor suffering withdrawal symptoms at the time he saw him. This officer also testified that the appellant had admitted using narcotics in the past.

Robinson was convicted under a California statue that made is a misdemeanor to either use narcotics or be addicted to the use of narcotics. Robinson appealed he conviction.

ISSUE

The issue is whether a state statute that criminalized an addiction to narcotics was constitutional.

RULE & APPLICATION

The court found that a statute that criminalizes a status (addiction)  to be a cruel and unusual punishment under the fourteen amendment and therefore unconstitutional.

The court recognized that the state of California has broad powers to regulate narcotic drugs traffic within its borders. That is the states can exercise its police powers to regulate the administration, sale, prescription and use of dangerous and habit-forming drugs. And in the interest of discouraging the violation of such laws, or in the interest of the general health or welfare of its inhabitants, a state might establish a program of compulsory treatment for those narcotics.

However, California has not construe the statute under which Robinson was convicted to be operative only upon proof of actual use of narcotics within the states jurisdiction. Instead, the jury was instructed that Robinson could be convicted under the statute if they simply found that Robinson’s “status “ or “chronic condition” was that of being “addicted to the use of narcotics.”

The court stated that; this statute, therefore, is not one which punishes a person for the use of narcotics, for their purchase, sale or possession, or for antisocial or disorderly behavior resulting from their administration. It is not a law which even purports to provide or require medical treatment. Rather, we deal with a statute which makes the “status” of narcotic addiction a criminal offense, for which the offender may be prosecuted “at any time before he reforms.” California  has said that a person can be continuously guilty of this offense, whether or not he has ever used or possessed any narcotics within the State, and whether or not he has been guilty of any antisocial behavior there.

We hold that a state law which imprisons a person thus afflicted as a criminal, even though he has never  touched any narcotic drug within the State or been guilty of any irregular behavior there, inflicts a cruel and unusual punishment in violation of the Fourteenth Amendment.

CONCLUSION

Robinson’s conviction was reversed.

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