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Robinson v. California | 370 U.S. 660 (1962)
Millions of people across the United States are addicted to illegal drugs. But say a state wants to brand these drug users as criminals solely based on their addiction – even if they haven’t used the drugs while present in that state. May a state criminalize a person’s mere addiction to drugs? The United States Supreme Court addressed this issue in Robinson versus California.
Los Angeles police officers pulled over a car in which Lawrence Robinson was a passenger. They noticed scabs, discolorations, and scar tissue on his arms, which were consistent with past drug injections. They arrested Robinson, despite the fact he wasn’t under the influence of drugs and didn’t possess any drugs.
A state prosecutor filed a misdemeanor charge under a California statute that criminalized narcotics addiction without any requirement of use or possession of drugs. Robinson had a jury trial in Los Angeles Municipal Court. At trial, officers testified about the physical condition of Robinson’s arms, and an officer with experience in narcotics cases claimed that Robinson’s physical condition indicated illegal drug use. Officers also testified that Robinson had confessed to injecting illegal drugs eight days before his arrest, although they didn’t say whether he had admitted to doing so within the state. The officers acknowledged that, when they arrested him, Robinson was neither under the influence of drugs nor experiencing withdrawal symptoms.
The jury convicted Robinson, and the trial judge sentenced him to 90 days in jail followed by a two-year term of parole during which he would be periodically tested for drugs. Robinson appealed to the California Superior Court, which affirmed his conviction. Robinson then sought review by the United States Supreme Court.
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