Robinson v. California 1962

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Robinson v. California 1962

Appellant: Lawrence Robinson

Appellee: State of California

Appellant's Claim: That convicting him for having a drug addiction was cruel and unusual punishment.

Chief Lawyer for Appellant: Samuel Carter McMorris

Chief Lawyer for Appellee: William E. Doran

Justices for the Court: Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, John Marshall Harlan II, Potter Stewart, Earl Warren

Justices Dissenting: Tom C. Clark, Byron R. White (Felix Frankfurter did not participate)

Date of Decision: June 25, 1962

Decision: The Supreme Court reversed Robinson's conviction.

Significance: With Robinson, the Supreme Court said it is cruel and unusual to convict someone for having an illness, such as drug addiction. Robinson helped eliminate status crimes such as vagrancy and homelessness.

Lawrence Robinson was on the streets of Los Angeles one evening when Officer Brown confronted him. Although Robinson was not doing anything wrong, Officer Brown questioned and searched Robinson for evidence of a crime. Brown found needle marks, scar tissue, and discoloration on Robinson's arms. Under questioning, Robinson admitted that he occasionally used illegal drugs. Officer Brown arrested Robinson and took him to the Central Jail in Los Angeles.

The next morning, Officer Lindquist examined Robinson's arms, both in person and in photographs taken the night before. Based on ten years of experience in the Narcotics Division of the Los Angeles Police Department, Officer Lindquist concluded that Robinson was injecting illegal drugs into his arms. According to Lindquist, Robinson admitted this under questioning.

Despite the marks on Robinson's arms, there was no evidence that he was under the influence of illegal drugs or having withdrawal symptoms when he was arrested. California, however, had a law that made it a crime to be addicted to drugs. People convicted under the law got a minimum of ninety days in jail. California charged Robinson with being a drug addict.

At his trial, Robinson said the marks on his arms were an allergy condition he got from shots in the military. Two witnesses for Robinson said the same thing. Robinson denied that he ever used or admitted to using illegal drugs. Officers Brown and Lindquist, however, testified to what they saw on Robinson's arms. The judge instructed the jury that even if there was no evidence that Robinson had used drugs in California, it could convict Robinson for being addicted to drugs while in California. The court said the law made the "condition or status" of drug addiction a crime.

The jury convicted Robinson, so he appealed to the Appellate Department of the Los Angeles County Superior Court. When that court ruled against him too, Robinson appealed to the U.S. Supreme Court.

Cruel and Unusual Punishment

With a 6–2 decision, the Supreme Court reversed Robinson's conviction. Writing for the Court, Justice Potter Stewart said drug addiction is an illness, not a crime. Punishing someone for an illness violates the Eighth Amendment of the U.S. Constitution, which bans cruel and unusual punishments.

Justice Stewart said states can fight against America's serious drug problem by making it illegal to manufacture, sell, buy, use, or possess illegal drugs. States also may protect their citizens from criminal activity by drug addicts by requiring addicts to get medical treatment.

California's law was different. It was meant to punish drug addicts, not cure them. Justice Stewart said punishing someone for having a drug addiction is like punishing someone for having a mental illness, leprosy, venereal disease, or the common cold. "Even one day in prison would be a cruel and unusual punishment for the 'crime' of having a common cold."

MANDATORY MINIMUM DRUG SENTENCES

W hen a jury convicts a criminal, the judge usually has the power to select a punishment, or sentence, to fit the crime. In the 1970s, however, America's war on drugs led to the enactment of mandatory minimum drug sentence laws. These laws forced judges to give drug offenders long prison sentences.

New York was the first state to enact a mandatory drug sentence law. Called the Rockefeller law after then Governor Nelson Rockefeller, it required a fifteen year sentence for anyone convicted of having at least four ounces or selling at least two ounces of an illegal drug. Thomas Eddy, one of the first to be convicted under New York's law, received 15 years to life in prison for selling two ounces of cocaine when he was a sophomore at State University of New York, Binghamton.

After over twenty-five years with such laws in the United States, many people call them a failure. The big drug dealers the laws were supposed to stop often escape punishment by turning in smaller dealers and users. America's jails are filled with first-time drug offenders serving stiff mandatory sentences. Meanwhile, overcrowded jails are forced to release rapists, robbers, and murderers to make room for drug users.

Supporters say mandatory minimum sentences are working. They say crime in the United States dropped in the 1990s because so many drug offenders were in jail. They also say tough mandatory sentences are the only way to fight drugs in the nation with the world's biggest drug problem.

Losing the War on Drugs

Justices Tom C. Clark and Byron R. White dissented, which means they disagreed with the Court's decision. In a dissenting opinion, Justice Clark said California's law was not designed to punish people for drug addiction. It was designed to put them in jail for at least 90 days to help them break the addiction.

In addition, Justice Clark said there is no difference between a person who uses drugs and a person who is addicted to drugs. Both are dangerous to society because drug use leads to health problems and criminal behavior. Convicting someone for a drug addiction is the same as convicting an alcoholic for public drunkenness. They are not status crimes, they are crimes that endanger societal health and welfare. Justice Clark said California should be allowed to protect people from such dangers.

Impact

Robinson could have been used to eliminate all crimes resulting from a person's voluntary use of drugs and alcohol. In Powell v. Texas (1968), however, the Supreme Court said addiction to alcohol cannot be used as a defense the crime of public drunkenness. Instead, Robinson has been used to strike down other types of status crimes, such as vagrancy and homelessness.