In Robinson v. California (1962), the Warren Court invalidated a California law that made it a crime for a person to be “addicted to narcotics.” Police officers charged Lawrence Roberts for violating the law after noticing scar tissue and scabs on his arms, apparently caused by excessive needle use. The Court held that “a state law which imprisons a person thus afflicted as a criminal, even though he has never touched any narcotic drug within the State or been guilty of any irregular behavior there, inflicts a cruel and unusual punishment in violation of the Fourteenth Amendment.”