## Facts

- NORML and individual plaintiffs sought declaratory and injunctive relief invalidating federal prohibitions on private possession and use of marijuana.
- Plaintiffs challenged provisions of the Controlled Substances Act (CSA), which classifies controlled substances into five schedules and places marijuana in Schedule I.
- Schedule I applies to substances Congress finds have a high potential for abuse, no currently accepted medical use in the United States, and a lack of accepted safety under medical supervision.
- Plaintiffs asserted marijuana did not satisfy Schedule I criteria and that criminalizing private use and possession violated constitutional protections.
- The court conducted five days of evidentiary hearings featuring expert testimony and studies addressing marijuana’s physical, psychological, and social effects; the evidence reflected ongoing scientific disagreement.
- After jurisdictional narrowing, the case proceeded against federal officials and focused on the federal statutory scheme.
- Plaintiffs advanced three constitutional theories: (1) a privacy right to private marijuana use, (2) equal protection principles applied through the Fifth Amendment’s Due Process Clause, and (3) the Eighth Amendment’s prohibition on cruel and unusual punishment.

## Issues

1. Whether the CSA’s prohibition of private possession and use of marijuana violates a constitutionally protected right to privacy.
2. Whether marijuana’s Schedule I classification and associated prohibitions are so irrational or arbitrary as to violate equal protection principles incorporated through the Fifth Amendment’s Due Process Clause.
3. Whether criminal penalties for private possession and use of marijuana constitute cruel and unusual punishment under the Eighth Amendment.

## Decision

- The three-judge district court rejected all constitutional challenges and upheld the CSA’s prohibition on private possession and use of marijuana.
- The court held there is no fundamental privacy right to use marijuana; therefore, rational-basis review applied and the statute was constitutional.
- The court held that marijuana’s Schedule I classification and the ban on private use were rational legislative judgments in an area marked by scientific dispute.
- The court held the penalties authorized for marijuana offenses were not grossly disproportionate and did not violate the Eighth Amendment.
- The court denied plaintiffs’ requests for declaratory and permanent injunctive relief, indicating policy change should occur through legislative or administrative processes.

## Legal Principles

- Private possession and use of marijuana is not a fundamental constitutional privacy right; challenges are evaluated under rational-basis review.
- Under rational-basis review, Congress may regulate drugs based on disputed or imperfect scientific evidence; classifications are upheld if any plausible rational justification supports them.
- Equal protection constraints on federal action, applied through the Fifth Amendment’s Due Process Clause, do not invalidate drug classifications that are not wholly arbitrary.
- Eighth Amendment review of legislatively set penalties is highly deferential; punishments are unconstitutional only if grossly disproportionate to the offense.
- Courts generally defer to Congress in complex social and scientific policy areas and will not reweigh contested evidence in place of legislative judgment.

## Conclusion

The court upheld the CSA’s criminalization of private marijuana possession and use and marijuana’s Schedule I status, finding no fundamental privacy right implicated, a rational basis for Congress’s regulatory choices despite scientific disagreement, and no gross disproportionality in the statutory penalties.


Nat’l Org. for the Reform of Marijuana Laws (NORML) v. Bell, 488 F. Supp. 123 (D.D.C. 1980)