Control and Treatment of Narcotic Addicts: Civil Commitment in California
Compulsory commitment procedures for persons addicted to the use of narcotics were first held to be constitutional and within the police powers of a state on the basis of dictum in the case of Robinson v. California. In the Robinson case, defendant was convicted under a California statute which made the "status" of being a narcotic addict a crime. The court held that this was cruel and unusual punishment within the meaning of the 8th and 14th Amendments. However, the court suggested that though the state may not punish for the status of addiction, compelling the addict to undergo treatment was not punishment at all.
Control and Treatment of Narcotic Addicts: Civil Commitment in California,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol6/iss1/3