Robinson v. California: Case Brief

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

Robinson v. California was the first case to apply the Eighth Amendment's prohibition of cruel and unusual punishment to the criminalization of certain acts. This lesson discusses the facts of the case and the Supreme Court's analysis and holding.

What is the Eighth Amendment?

What do the Constitution and a late-night horror film have in common? Here are a few hints: Dissection. Disembowelment. Death by burning. Drawing and quartering.

Under the Eighth Amendment to the Constitution, the government is prohibited from inflicting cruel and unusual punishments on individuals convicted of crimes. Over the years, a number of gruesome and medieval measures (like the ones just mentioned), have been banned as unconstitutional forms of criminal punishment.

In 1962, the Supreme Court of the United States broadened the reach of the Eighth Amendment and declared that the criminalization of certain acts may be unconstitutional.

The Facts of Robinson v. California

A California police officer happened upon the defendant, Robinson, out and about on the streets of Los Angeles. The officer observed scars and discoloration on Robinson's arm. Recognizing these markings as the tell-tale signs of drug addiction, the officer asked Robinson if he used drugs. Robinson admitted that he had occasionally used drugs and had done so just eight days prior--an admission Robinson later denied.

Robinson was arrested and charged with a misdemeanor. At the time, California had a law on the books that made drug addiction an illegal act. Robinson was convicted and ordered to serve 90 days in jail. He appealed his conviction all the way to the Supreme Court.

The Question Presented to the Supreme Court

In Robinson v. California, the Supreme Court was tasked with determining whether the criminalization of certain acts, like drug addiction, violated the Eighth Amendment's prohibition of 'cruel and unusual' punishment.

The Holding and Analysis of the Supreme Court

The Supreme Court held that the California law that made drug addiction a crime violated the Eighth Amendment of the United States Constitution.

Up until the Robinson case, the Supreme Court had only considered criminal punishments as subject to the Eighth Amendment's limitations. The Robinson decision marked the first time that the Supreme Court determined that the criminalization of an activity or behavior could constitute 'cruel and unusual' punishment.

In reaching its conclusion, the Supreme Court reasoned that drug addiction is a disease, and not a crime. The Supreme Court compared drug addiction to the 'common cold' in order to illustrate the absurdity of criminalizing an illness.

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