Robinson v. California

Supreme Court of the United States · 1962 · Criminal Law

370 U.S. 660 (1962)

Updated August 1, 2026

Criminal Lawstatus crimesEighth AmendmentFourteenth Amendmentcruel and unusual punishmentstatus offensenarcotic addictioncriminalization of status

Facts

California made it a criminal offense for a person to "be addicted to the use of narcotics." Police officers testified that appellant had needle marks, scabs, and discoloration on his arms and had admitted past narcotics use; appellant denied using narcotics and offered an innocent explanation for the marks. The trial judge instructed the jury that the statute covered both the act of using narcotics and the status or condition of being addicted, and that appellant could be convicted if the jury found either. The jury returned a general verdict of guilty, making it impossible to know whether the conviction rested on use or on status alone.

Issue

Whether a state may, consistent with the Fourteenth Amendment, make the status or condition of being addicted to narcotics a criminal offense. More specifically, whether California's statute, as construed to permit conviction based solely on the status of addiction, inflicts cruel and unusual punishment.

Rule

A state law that makes the status of narcotic addiction itself a criminal offense, and punishes a person as a criminal for that condition even though he has not used or possessed narcotics within the State or engaged in antisocial behavior there, inflicts cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nevada enacts a statute making it a misdemeanor for any person in Reno to "be a drug addict," punishable by up to 30 days in jail. At trial, the prosecution proves only that Elena Cruz has old track marks and expert testimony that she suffers from opioid addiction; there is no proof she possessed or used drugs in Nevada or engaged in any disorderly conduct there.

If Elena challenges her conviction under the Federal Constitution, what is the strongest argument?

Explanation. The governing rule is that the Eighth Amendment, applied to the states through the Fourteenth Amendment, forbids criminal punishment for the status of narcotic addiction itself. The majority distinguished valid laws punishing manufacture, sale, purchase, possession, or use from an invalid law punishing a chronic condition. The sentence length does not save the statute, because the constitutional question turns on what is being punished, not punishment in the abstract.