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Robinson v. California
 | |
| Robinson v. California | |
| Reference: 370 U.S. 660 | |
| Term: 1962 | |
| Important Dates | |
| Argued: April 17, 1962 Decided: June 25, 1962 | |
| Outcome | |
| Superior Court of Los Angeles County, California reversed | |
| Majority | |
| Potter Stewart • Earl Warren • Hugo Black • William Brennan | |
| Concurring | |
| William Douglas • John Harlan II | |
| Dissenting | |
| Tom Clark • Byron White | |
Robinson v. California is a case decided on June 25, 1962, by the United States Supreme Court that incorporated the protection against cruel and unusual punishment of the Eighth Amendment of the U.S. Constitution to states. The case concerned a California statute that criminalized narcotics addiction. The Supreme Court reversed the decision of the Superior Court of Los Angeles County, California.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that punishing an individual for being addicted to drugs was cruel and unusual punishment. To read more about the impact of Robinson v. California click here.
Background
An individual was convicted for being addicted to narcotics based on a California statute that criminalized narcotics addiction. The defendant appealed on the grounds that he had not been engaged in any illegal conduct, but the conviction was affirmed by the Superior Court of Los Angeles County, California.[1][3]
Oral argument
Oral argument was held on April 17, 1962. The case was decided on June 25, 1962.[1]
Decision
The Supreme Court decided 6-2 to reverse the decision of the Superior Court of Los Angeles County, California. Justice Potter Stewart delivered the opinion of the court. Justices William Douglas and John Harlan II wrote concurring opinions. Justices Tom Clark and Byron White wrote dissenting opinions. Justice Felix Frankfurter did not participate in the decision.[2]
Opinions
Opinion of the court
Justice Potter Stewart, writing for the court, argued that narcotics addiction is an illness and it is therefore cruel and unusual punishment to imprison an individual for it. Stewart contended that the state would not imprison someone for being mentally ill or having a disease and that addiction should be viewed in the same way.[2]
| “ | We cannot but consider the statute before us as of the same category. In this Court, counsel for the State recognized that narcotic addiction is an illness. Indeed, it is apparently an illness which may be contracted innocently or involuntarily. 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. To be sure, imprisonment for ninety days is not, in the abstract, a punishment which is either cruel or unusual. But the question cannot be considered in the abstract. Even one day in prison would be a cruel and unusual punishment for the 'crime' of having a common cold.[4] | ” |
| —Potter Stewart, majority opinion in Robinson v. California[2] | ||
Concurring opinions
Justice William Douglas, in a concurring opinion, agreed with the decision of the court and emphasized why the state law was cruel and unusual punishment. Douglas posited that addiction is an illness and that it is unconstitutional to punish someone for being ill.[2]
| “ | We should show the same discernment respecting drug addiction. The addict is a sick person. He may, of course, be confined for treatment or for the protection of society. Cruel and unusual punishment results not from confinement, but from convicting the addict of a crime. The purpose of § 11721 is not to cure, but to penalize.
|
” |
| —William Douglas, concurring opinion in Robinson v. California[2] | ||
Justice John Harlan II, in a concurring opinion, argued that the state did not have evidence that the defendant had committed a crime.[2]
| “ | I am not prepared to hold that, on the present state of medical knowledg,e it is completely irrational, and hence unconstitutional, for a State to conclude that narcotics addiction is something other than an illness, nor that it amounts to cruel and unusual punishment for the State to subject narcotics addicts to its criminal law. Insofar as addiction may be identified with the use or possession of narcotics within the State (or, I would suppose, without the State), in violation of local statutes prohibiting such acts, it may surely be reached by the State's criminal law. But in this case, the trial court's instructions permitted the jury to find the appellant guilty on no more proof than that he was present in California while he was addicted to narcotics. * Since addiction alone cannot reasonably be thought to amount to more than a compelling propensity to use narcotics, the effect of this instruction was to authorize criminal punishment for a bare desire to commit a criminal act.[4] | ” |
| —John Harlan II, concurring opinion in Robinson v. California[2] | ||
Dissenting opinions
Justice Tom Clark, in a dissenting opinion, argued that the state statute provided a treatment for addiction, rather than punishment.[2]
| “ | Properly construed, the statute provides a treatment, rather than a punishment. But even if interpreted as penal, the sanction of incarceration for 3 to 12 months is not unreasonable when applied to a person who has voluntarily placed himself in a condition posing a serious threat to the State. Under either theory, its provisions for 3 to 12 months' confinement can hardly be deemed unreasonable when compared to the provisions for 3 to 24 months' confinement under § 5355 which the majority approves.[4] | ” |
| —Tom Clark, dissenting opinion in Robinson v. California[2] | ||
Justice Byron White, in a dissenting opinion, argued that the state had the authority to convict the defendant for narcotics use.[2]
| “ | I am not at all ready to place the use of narcotics beyond the reach of the States' criminal laws. I do not consider appellant's conviction to be a punishment for having an illness or for simply being in some status or condition, but rather a conviction for the regular, repeated or habitual use of narcotics immediately prior to his arrest and in violation of the California law. As defined by the trial court, addiction is the regular use of narcotics and can be proved only by evidence of such use. To find addiction in this case, the jury had to believe that appellant had frequently used narcotics in the recent past. California is entitled to have its statute and the record so read, particularly where the State's only purpose in allowing prosecutions for addiction was to supersede its own venue requirements applicable to prosecutions for the use of narcotics and in effect to allow convictions for use where there is no precise evidence of the county where the use took place.[4] | ” |
| —Byron White, dissenting opinion in Robinson v. California[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Incorporation
Robinson v. California established that the Eighth Amendment's protection against cruel and unusual punishment applies to state court criminal proceedings.
The decision in this case was responsible for incorporating the protection against cruel and unusual punishment to state governments. Incorporation is the process of binding a fundamental right onto the states through a Supreme Court decision.[2][5]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Robinson v. California," accessed September 6, 2022
- ↑ 2.00 2.01 2.02 2.03 2.04 2.05 2.06 2.07 2.08 2.09 2.10 2.11 2.12 Justia, "Robinson v. California, 370 U.S. 660 (1962)," accessed September 6, 2022
- ↑ 3.0 3.1 LexisNexis, "Robinson v. California - 370 U.S. 660, 82 S. Ct. 1417 (1962)," accessed September 6, 2022
- ↑ 4.0 4.1 4.2 4.3 4.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Bill of Rights Institute, "Incorporation," accessed September 6, 2022
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