State v. Robinson
2011 UT 30
| Utah | 2011Background
- Robinson was charged with unlawful possession or use of a controlled substance based on methamphetamine in his blood under Utah's measurable amount provision.
- The charge arises from Utah Controlled Substances Act provisions prohibiting knowingly and intentionally possessing or using any measurable amount in the body.
- Robinson was stopped for suspected insurance violation; he failed sobriety tests and was arrested for DUI, with methamphetamine detected in blood after testing.
- At preliminary hearing, Robinson challenged the measurable amount provision as unconstitutional status offense under Robinson v. California; the district court denied the motion to quash.
- Robinson pled guilty to knowingly and intentionally possessing or using methamphetamine; he reserved appeal of the bindover denial.
- The Utah Supreme Court certified the question on constitutionality and addressed Utah and U.S. constitutional challenges to the provision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does measurable amount violate due process? | Robinson asserts due process violation for punishing involuntary conduct. | Robinson contends the provision criminalizes status or involuntary exposure. | No due process violation; requires knowing and intentional introduction. |
| Does measurable amount violate uniform operation of laws? | Robinson argues disparate treatment within similarly situated offenders. | Robinson argues uniform application but with sub-classifications by substance type. | Not violated overall; sub-classification based on substance does not undermine uniform operation; rational basis supports disparity. |
| Does measurable amount violate Robinson v. California principles? | Robinson claims it punishes a status (being under influence) akin to addiction. | Measurable amount punishes active use/being under influence, not mere status. | Does not violate Robinson; punishs active use while in Utah and requires knowing and intentional conduct. |
| Does measurable amount violate the Fourteenth Amendment due process? | Robinson argues due process protections extend to federal level due process. | State notice and opportunity to comply safeguard due process. | No federal due process violation; similar rationale to state due process holding. |
Key Cases Cited
- Robinson v. California, 370 U.S. 660 (Supreme Court, 1962) (cannot criminalize addiction as status; may punish active use)
- Powell v. Texas, 392 U.S. 514 (Supreme Court, 1968) (punishment for appearance while intoxicated permissible; use at issue)
- State v. Drej, 2010 UT 35, 233 P.3d 476 (Utah Supreme Court, 2010) (rational basis scrutiny for classifications in state law)
- Blue Cross & Blue Shield of Utah v. Utah State Tax Comm'n, 2009 UT 36, 211 P.3d 382 (Utah Supreme Court, 2009) (principles on reviewing classifications and legitimate objectives)
- Swayne v. L.D.S. Social Services, 795 P.2d 637 (Utah, 1990) (due process requires reasonable opportunity to comply with statute)
- Sherpix, Inc. v. Brockert, 512 F.2d 1361 (D.C. Cir., 1975) (notice and standards; vagueness concerns in due process)