Sunday, November 17, 2013

Robinson v. California case brief

Robinson v. California case brief summary
370 U.S. 660 (1962)


CASE SYNOPSIS
Defendant appealed a decision from the Appellate Department, Superior Court of California, Los Angeles County, which upheld a trial court's judgment that convicted him of being addicted to the use of narcotics in violation of Cal. Health & Safety Code § 11721.

CASE FACTS
A jury found defendant guilty under Cal. Health & Safety Code § 11721 for being addicted to the use of narcotics, a conviction that was affirmed on appeal. Defendant sought further review from the United States Supreme Court.

DISCUSSION

  • The Court reviewed the record, which included a police officer's testimony that defendant had scar tissue and discoloration on the inside of his arm, as well as needle marks and a scab below the crook of the elbow, which the officer believed was the result of injections by hypodermic needles. 
  • The officer also testified that defendant admitted to the occasional use of narcotics. 
  • At the time of his arrest, defendant was not engaged in any illegal conduct, and there was no proof that he had actually used narcotics within California. 
  • The Court concluded that § 11721 made the status of being addicted to the use of narcotics a criminal offense, whether or not he ever used or possessed narcotics within California or had been guilty of any antisocial behavior there. 
  • The Court found § 11721 to be unconstitutional and in violation of U.S. Constitutional amendment XIV for inflicting cruel and unusual punishment.

CONCLUSION
The Court reversed the decision of the state courts and held that the California statute was unconstitutional.

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