Robinson v.

California

Facts: 

The Defendant was arrested by a police officer who observed the Defendant’s
arms to be in a condition consistent with heavy drug use, i.e. needle marks,
scabs, scar tissue. Further, the Defendant admitted to the occasional use of
narcotics. He was charged with violating a California statute that makes it a
criminal offense for a person to “be addicted to the use of narcotics.” The
Defendant was convicted by a jury.

Issue: 

Is a statute criminalizing drug addiction constitutional?

Held: 

No. The statute makes the “status” of being addicted to narcotics illegal “at any
time before he reforms.” Since addiction can properly be termed a disease, the
United States Supreme Court (Supreme Court) likens this statute to making it a
crime to be mentally ill or to have a venereal disease. Certainly, criminalizing
having the disease would be universally thought to be cruel and unusual
punishment.