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- Criminal Law and Procedure
Robinson v. California 1962
Author | Daniel Brannen, Richard Hanes, Elizabeth Shaw |
Pages | 319-323 |
Page 319
Appellant: Lawrence Robinson
Appellee: State of California
Appellant's Claim: That convicting him for having a drug addiction was cruel and unusual punishment.
Chief Lawyer for Appellant: Samuel Carter McMorris
Chief Lawyer for Appellee: William E. Doran
Justices for the Court: Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, John Marshall Harlan II, Potter Stewart, Earl Warren
Justices Dissenting: Tom C. Clark, Byron R. White (Felix Frankfurter did not participate)
Date of Decision: June 25, 1962
Decision: The Supreme Court reversed Robinson's conviction.
Significance: With Robinson, the Supreme Court said it is cruel and unusual to convict someone for having an illness, such as drug addiction. Robinson helped eliminate status crimes such as vagrancy and homelessness.
Lawrence Robinson was on the streets of Los Angeles one evening when Officer Brown confronted him. Although Robinson was not doing anything wrong, Officer Brown questioned and searched Robinson for evidence of a crime. Brown found needle marks, scar tissue, and discoloration on Robinson's arms. Under questioning, Robinson admitted that
Page 320
he occasionally used illegal drugs. Officer Brown arrested Robinson and took him to the Central Jail in Los Angeles.
The next morning, Officer Lindquist examined Robinson's arms, both in person and in photographs taken the night before. Based on ten years of experience in the Narcotics Division of the Los Angeles Police Department, Officer Lindquist concluded that Robinson was injecting illegal drugs into his arms. According to Lindquist, Robinson admitted this under questioning.
Despite the marks on Robinson's arms, there was no evidence that he was under the influence of illegal drugs or having withdrawal symptoms when he was arrested. California, however, had a law that made it a crime to be addicted to drugs. People convicted under the law got a minimum of ninety days in jail. California charged Robinson with being a drug addict.
At his trial, Robinson said the marks on his arms were an allergy condition he got from shots in the military. Two witnesses for Robinson said the same thing. Robinson denied that he ever used or admitted to using illegal drugs. Officers Brown and Lindquist, however, testified to what they saw on Robinson's arms. The judge instructed the jury that even if there was no...
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