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{{Infobox SCOTUS case
|Litigants=Robinson v. California
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|ParallelCitations=82 S. Ct. 1417; 8 [[L. Ed. 2d]] 758; 1962 [[U.S. LEXIS]] 850
|Prior=Appeal from the Appellate Department, Superior Court of California of the County of Los Angeles.
|Subsequent=Rehearing denied, {{ussc|371|905|1962|el=no}}.
|Holding=Punishing a person for a medical condition is a violation of the Eighth Amendment ban on cruel and unusual punishment.
|Majority=Stewart
|JoinMajority=Warren, Black, Douglas, Harlan, Brennan
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|LawsApplied=[[Eighth Amendment to the United States Constitution|U.S. Const. amends. VIII]], [[Fourteenth Amendment to the United States Constitution|XIV]]
}}
'''''Robinson v. California''''', 370 U.S. 660 (1962),
==Background==
Robinson was stopped by a police officer who observed "tracks" on Robinson's arms from heroin use. The officer claimed Robinson admitted that he had occasionally injected [[narcotics]], though Robinson denied admitting this, and also denied being an addict. The police arrested him under California law making it a misdemeanor to "be addicted to the use of narcotics"; Robinson was convicted in the Municipal Court of Los Angeles, and sentenced to 90 days' imprisonment. Robinson appealed his conviction to the Appellate Department of the [[Superior Court of California of the County of Los Angeles|Los Angeles County Superior Court]], which upheld his conviction. He then appealed to the [[Supreme Court of the United States]].
California Health and Safety Code § 11721 provided: "No person shall use, or be under the influence of, or be addicted to the use of narcotics, excepting when administered by or under the direction of a person licensed by the State to prescribe and administer narcotics."
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Until the ''Robinson'' opinion, some Eighth Amendment decisions addressed whether the method of punishment was cruel and unusual.<ref>See generally Anthony F. Granucci, ''Nor Cruel and Unusual Punishments Inflicted: The Original Meaning'', 57 {{smallcaps|Cal. L. Rev.}} 839 (1969).</ref> For example:
* In ''[[Wilkerson v. Utah|Wilkerson v. State of Utah]]''
* In ''[[Electric chair#First execution|In re Kemmler]]''
* In ''[[Trop v. Dulles]]''
* The last in this line of cases before ''Robinson'' was ''[[Louisiana ex rel. Francis v. Resweber
However, in ''[[Weems v. United States]]'', 217 U.S. 349 (1910), in which a punishment of twelve years in irons at hard and painful labor was imposed for the crime of falsifying public records, the Court held that the penalty was cruel in its ''excessiveness'' and unusual in its character (''i.e.'', its disproportionality).<ref>{{ussc|name=Weems v. United States|volume=217|page=349|pin=|year=1910}}.</ref> The Court quoted ''[[obiter dicta]]'' by Justice Field in dissent in [https://supreme.justia.com/cases/federal/us/144/323/ ''O'Neil v. Vermont''], 144 U.S. 323 (1892): "the inhibition was directed not only against punishments which inflict torture, 'but against all punishments which, by their excessive length or severity, are greatly disproportioned to the offenses charged.'".<ref>''Weems''
==Supreme Court ruling in ''Robinson''==
A fragmented Court reversed the state's judgment. The main opinion, by Justice [[Potter Stewart]] (joined by Justices Warren, Black and Brennan) in combination with Douglas's concurring opinion, recognized that drug addiction is a disease, and that it is unconstitutional to impose punishment for having a disease.<ref>''Robinson'', 370 U.S. at
Justice Clark dissented, first, because "[p]roperly construed, the statute provides a treatment, rather than a punishment." Second, "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."<ref>370 U.S. at 685.</ref>
Justice [[Byron White]] dissented. He argued, first, that "on this record, it was within the power of the State of California to confine him by criminal proceedings for the use of narcotics or for regular use amounting to habitual use."<ref>370 U.S. at 688.</ref> Second, the Court "has effectively removed California's power to deal effectively with the recurring case under the statute where there is ample evidence of use but no evidence of the precise location of use. Beyond this, it has cast serious doubt upon the power of any State to forbid the use of narcotics under threat of criminal punishment."<ref name=White689>370 U.S. at 689.</ref> Finally, he said that the Court was using "cruel and unusual punishment" as a disguise of "[[substantive due process]]":
<blockquote> If this case involved economic regulation, the present Court's allergy to substantive due process would surely save the statute and prevent the Court from imposing its own philosophical predilections upon state legislatures or Congress. I fail to see why the Court deems it more appropriate to write into the Constitution its own abstract notions of how best to handle the narcotics problem, for it obviously cannot match either the States or Congress in expert understanding.<ref>370 U.S. at 689.</ref></blockquote>▼
▲<blockquote>
==Subsequent developments==▼
▲==Subsequent developments==
===Robinson's death===
By June 25, 1962, the day the Court handed down this decision,
===Later cases in Supreme Court===
Following the ''Robinson'' decision, the Court upheld a law criminalizing [[public intoxication|public drunkenness]] under ''[[Powell v. Texas]]'',<ref>{{ussc|name=Powell
In [[City of Grants Pass v. Johnson]], the court declined to extend the argument in Robinson to laws prohibiting even homeless people from sleeping in public. In a concurring opinion, Justice Thomas said that Robinson was wrongly decided. In a dissent, three judges argued that "sleep is not a crime" and based on Robinson, it is illegal to criminalize the status of homelessness.<ref>{{Cite web |title=US Supreme Court says cities can punish people for sleeping in public places |url=https://www.opb.org/article/2024/06/28/supreme-court-grants-pass-punish-homeless/ |access-date=2024-06-28 |website=opb |language=en}}</ref>
▲Following the ''Robinson'' decision, the Court upheld a law criminalizing [[public intoxication|public drunkenness]] under ''[[Powell v. Texas]]'', 392 U.S. 514, 517 (1968), despite the argument advanced by some members of the Court that ''Robinson'' held that it was not criminal to give in to the irresistible compulsions of a "disease" (alcoholism)
===="Disproportionality" cases based on ''Robinson''====
The first case in which the Supreme Court applied the expanded "cruel and unusual" principle of ''Robinson'' to cases in which the penalty was considered disproportionate or excessive relative to the crime was ''Coker v. Georgia''
In ''[[Rummel v. Estelle]]''
▲The first case in which the Supreme Court applied the expanded "cruel and unusual" principle of ''Robinson'' to cases in which the penalty was considered disproportionate or excessive relative to the crime was ''Coker v. Georgia'', 433 U.S. 584 (1977). The Court held that, because of the disproportionality, it was a violation of the Cruel and Unusual Punishments Clause to impose capital punishment for rape of an adult woman.
In ''[[Solem v. Helm]]''
▲In ''Rummel v. Estelle'', 445 U.S. 263 (1980), the Court held that it did ''not'' constitute cruel and unusual punishment to impose a life sentence, under a recidivist statute, upon a defendant who had been convicted, successively, of fraudulent use of a credit card to obtain $80 worth of goods or services, passing a forged check in the amount of $28.36, and obtaining $120.75 by false pretenses. The Court said that "one could argue without fear of contradiction by any decision of this Court that for crimes concededly classified and classifiable as felonies, that is, as punishable by significant terms of imprisonment in a state penitentiary, the length of the sentence actually imposed is purely a matter of legislative prerogative."<ref>445 U.S. at 274.</ref> Despite its unwillingness to find unconstitutional disproportionality, the Court conceded, ""This is not to say that a proportionality principle would not come into play in the extreme example mentioned by the dissent, . . . if a legislature made overtime parking a felony punishable by life imprisonment."<ref>445 U.S. at 274, n. 11.</ref>
In ''[[Harmelin v. Michigan]]''
▲In ''Solem v. Helm'', 463 U. S. 277 (1983), a 5-4 majority set a conviction aside under the Eighth Amendment, because it was disproportionate—a sentence of life imprisonment without possibility of parole, imposed under a recividist statute for successive offenses that included three convictions of third-degree burglary, one of obtaining money by false pretenses, one of grand larceny, one of third-offense driving while intoxicated, and one of writing a "no account" check with intent to defraud. The Court later characterized this decision as "scarcely the expression of clear and well accepted constitutional law."<ref>''Harmelin v. Michigan'', 501 U.S. 957, 965 (1991)</ref>
▲In ''Harmelin v. Michigan'', 501 U.S. 957 (1991), the Court examined the historical basis for the Eighth Amendment, found it based on the "cruel and unusual Punishments" provision of the English Declaration of Rights of 1689, and suggested that it is "most unlikely that the English Cruel and Unusual Punishments Clause was meant to forbid 'disproportionate' punishments."<ref>501 U.S. at 975.</ref> The judgment of the Court was that life imprisonment without parole for the crime of possession of more than 650 grams of cocaine did not violate the Eighth Amendment.
===Later cases in lower courts===
In ''State v. Margo'',<ref>40 N.J. 188, 191 A.2d 43 (1963).</ref> the Supreme Court of New Jersey first distinguished ''Robinson'' by stating, "In ''Robinson'' it was held that a statute of California which made it a criminal offense to 'be addicted to the use of narcotics' inflicted cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. But Margo "was convicted of being under the influence of a narcotic drug, heroin." Margo's conviction was not for addiction, as was Robinson's. The court then declared:
<blockquote>We see no reason why, if a person may constitutionally be punished for using a drug, he may not be punished for being under its `influence,' for realistically the use of a drug offends society's interests precisely because of its baleful influence upon the person and the harm to which that influence may lead. In other words, being under the influence of a drug is itself antisocial behavior. It is not some latent or passive proclivity; it is an active state, voluntarily induced and laden with a present capacity for further injury to society. We think society may use the criminal process to protect itself against that harm. Robinson is not to the contrary.<ref>40 N.J. at 190, 191 A.2d at 45.</ref></blockquote>▼
▲We see no reason why, if a person may constitutionally be punished for using a drug, he may not be punished for being under its `influence,' for realistically the use of a drug offends society's interests precisely because of its baleful influence upon the person and the harm to which that influence may lead. In other words, being under the influence of a drug is itself antisocial behavior. It is not some latent or passive proclivity; it is an active state, voluntarily induced and laden with a present capacity for further injury to society. We think society may use the criminal process to protect itself against that harm. Robinson is not to the contrary.<ref>40 N.J. at 190, 191 A.2d at 45.</ref></blockquote>
The court therefore unanimously affirmed the conviction.
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In ''Salas v. State'',<ref>365 S.W.2d 174 (Tex. Crim. App. 1963)</ref> the defendant was convicted of being "unlawfully under the influence of a narcotic drug."<ref>365 S.W.2d at 175.</ref> The court affirmed the conviction because it considered the ''Robinson'' holding limited to addiction. Salas appealed to the Supreme Court, but the appeal was dismissed "for want of substantial Federal question."<ref>Appeal dismissed ''sub nom. Salas v. Texas'', 375 U.S. 15 (1963),</ref>
In ''State v. Brown'',<ref>103 Ariz. 289, 440 P.2d 909 (1968) (''en banc'').</ref> the Arizona Supreme Court (''en banc'') refused to hold the state without power to criminalize drug use. It said ''Robinson'' applied only to criminalizing ''addiction'', not ''use'' or ''being under the influence''. Here, "Brown was convicted of being 'under the influence of
==See also==
* [[List of United States Supreme Court cases, volume 370]]
==References==
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==External links==
*
| case=''Robinson v. California'', {{ussc|370|660|1962|el=no}}
| findlaw=https://caselaw.findlaw.com/us-supreme-court/370/660.html
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