Robinson v. California
370 U.S. 660 (1962)

  • California had a law that made it a criminal offense for a person to “be addicted to the use of narcotics.”
  • Robinson was arrested after the police noticed that he had needle marks. He was charged with being an addict.
  • At Trial, the judge told the jury that they could find Robinson guilty if they found either that he was “of the status” or has “committed the act” of being an addict.
    • Basically, that the defendant wither used drugs within the jurisdiction or was addicted to drugs while being in the jurisdiction.
  • The Trial Court convicted Robinson of being a drug addict and sentenced to 90 days in prison. He appealed.
  • The Appellate Court upheld the conviction. Robinson appealed.
  • The US Supreme Court overturned the conviction.
    • The US Supreme Court found that the California law was cruel and unusual punishment since drug addiction “is apparently an illness”, and California was attempting to punish people based on their being sick, rather than for any specific act.
      • The Court noted that a person guilty under this law might never have taken any narcotics at all while in California, nor engaged in any destructive behavior.
    • The Court found that in order for one to be charged with a criminal act, it was necessary for one to commit an act. A State cannot criminalize a status.