In Robinson, the U.S. Supreme Court held that the Eighth Amendment precludes punishment for a ‘‘status offense’’ in the absence of criminal behavior. The defendant was charged under a California statute that forbade ‘‘one to be addicted to the use of narcotics.’’ At the close of evidence, the judge instructed the jury that it could convict if it found that the defendant had merely been addicted to illegal narcotics while in the court’s jurisdiction. The defendant was convicted and sentenced to serve ninety days in jail.
In a fractured opinion, the Supreme Court held that the conviction violated the defendant’s Eighth and Fourteenth Amendment rights. The Court distinguished a state’s authority to punish a defendant for using narcotics from the state’s authority to punish him for being addicted to narcotics. Finding addiction to be more like a status than an act, the Court drew a parallel between addiction and mental illness, reasoning that punishment for addiction would be akin to punishing the insane for their insanity. Even though the Court found that a state may lawfully confine a mentally ill person for medical treatment, the justices differentiated treatment from punishment, reasoning that ‘‘[e]ven one day in prison would be cruel and unusual’’ as punishment for a status similar to mental illness. Robinson later provided foundation for the Court’s 2002 conclusion that execution of mentally ill defendants would be cruel and unusual (Atkins v. Virginia ).
Shortly after issuing the Robinson decision, the Court narrowed the scope of its holding, refusing to constitutionalize an insanity test and holding that punishment of an act somewhat compelled by addiction could survive constitutional scrutiny (Powell v. State of Texas ).
KRISTOPHER B. STEVENS
References and Further Reading
Cases and Statutes Cited
See also Bill of Rights: Structure; Capital Punishment: Eighth Amendment Limits; Cruel and Unusual Punishment (VIII); Cruel and Unusual Punishment Generally; Fourteenth Amendment; Furman v. Georgia, 408 U.S. 238 (1972); Powell v. Texas, 392 U.S. 514 (1968); Status Offenses