California had a law that made
it a criminal offense for a person to "be addicted to the use of
narcotics."
Robinson was arrested after
the police noticed that he had needle marks. He was charged with being an
addict.
At Trial, the judge told the
jury that they could find Robinson guilty if they found either that he was
"of the status" or has "committed the act" of being an
addict.
Basically, that the
defendant wither used drugs within the jurisdiction or was addicted to
drugs while being in the jurisdiction.
The Trial Court convicted
Robinson of being a drug addict and sentenced to 90 days in prison. He
appealed.
The Appellate Court upheld the
conviction. Robinson appealed.
The US Supreme Court
overturned the conviction.
The US Supreme Court found
that the California law was cruel and unusual punishment since drug addiction "is apparently an
illness", and California was attempting to punish people based on
their being sick, rather than for any specific act.
The Court noted that a
person guilty under this law might never have taken any narcotics at all
while in California, nor engaged in any destructive behavior.
The Court found that in
order for one to be charged with a criminal act, it was necessary for one
to commit an act. A State cannot
criminalize a status.
