## Facts

- California Health and Safety Code § 11721 made it a misdemeanor to “use,” “be under the influence of,” or “be addicted to the use of narcotics,” except when medically administered.
- California courts construed the “addicted” clause to criminalize the status of addiction itself, permitting prosecution at any time while the condition continued, regardless of acts in California.
- Robinson was charged and convicted in a Los Angeles municipal court for being “addicted to the use of narcotics” and was sentenced to county jail.
- At trial, police officers testified they observed scarring, discoloration, and needle marks on Robinson’s arms consistent with intravenous narcotics use.
- An officer testified Robinson admitted “occasional use” of narcotics; another officer, relying on extensive narcotics experience, opined the marks were caused by nonsterile hypodermic injections.
- Robinson denied narcotics use or addiction and attributed the marks to an allergic condition from military service; he offered corroborating witnesses.
- The trial judge instructed the jury that the statute criminalized either an act (“use”) or a state of being (“addicted”).
- State appellate courts affirmed, and the U.S. Supreme Court reviewed on direct appeal.

## Issues

1. Whether a statute that criminalizes the status of being “addicted to the use of narcotics,” as construed to require no proscribed conduct, violates the Eighth Amendment’s Cruel and Unusual Punishments Clause as applied to the states through the Fourteenth Amendment.

## Decision

- The Supreme Court reversed in a 6–2 decision.
- The Court held that, as construed and applied to punish the status of narcotic addiction alone, § 11721 imposed cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments.
- The Court limited its holding to status-based punishment and did not invalidate laws directed at acts such as use, possession, purchase, or sale of narcotics.

## Legal Principles

- The Eighth Amendment’s ban on cruel and unusual punishments applies to the states through the Fourteenth Amendment.
- A state may not make a person’s status or condition a criminal offense where liability does not require an act or conduct; imprisonment for a condition treated as an illness is constitutionally impermissible.
- Criminal laws may target conduct related to narcotics (e.g., use or possession), but punishment solely for being an addict, without a proscribed act, exceeds constitutional limits.

## Conclusion

The Court held that California could not constitutionally imprison a person for the bare status of narcotic addiction, treating addiction as an illness and concluding that status-based criminal punishment is cruel and unusual under the Eighth Amendment as incorporated against the states.


Robinson v. California, 370 U.S. 660 (1962)