Robinson v. California, 370 U.S. 660 (1962), is the first landmark decision of the United States Supreme Court in which the Eighth Amendment of the Constitution was interpreted to prohibit criminalization of particular acts or conduct, as contrasted with prohibiting the use of a particular form of punishment for a crime. In Robinson, the Court struck down a California law that criminalized being addicted to narcotics. Background Robinson was stopped by a police officer who observed "tracks" on Robinson's arms from heroin use. The officer claimed Robinson admitted that he had occasionally injected narcotics, though Robinson denied admitting this, and also denied being an addict. The police arrested him under California law making it a misdemeanor to "be addicted to the use of narcotics"; Robinson was convicted in the Municipal Court of Los Angeles, and sentenced to 90 days' imprisonment. Robinson appealed his conviction to the Appellate Department of the Los Angeles County Superior Court, which upheld his conviction. He then appealed to the Supreme Court of the United States. California Health and Safety Code § 11721 provided: "No person shall use, or be under the influence of, or be addicted to the use of narcotics, excepting when administered by or under the direction of a person licensed by the State to prescribe and administer narcotics." Previous Eighth Amendment rulings Until the Robinson opinion, some Eighth Amendment decisions addressed whether the method of punishment was cruel and unusual. For example: In Wilkerson v. State of Utah, the Supreme Court held that it was not a cruel and unusual punishment for the Territory of Utah to execute a criminal by shooting him, rather than the more common use of hanging. The Court said that cruel and unusual punishments include "punishments of torture" and cases "where the prisoner was drawn or dragged to the place of execution, in treason; or where he was emboweled alive, beheaded, and quartered, in high treason," as well as "public dissection in murder, and burning alive in treason committed by a female." But execution by shooting was not in the category. In In re Kemmler, the Supreme Court held execution by electrocution not to be a cruel and unusual punishment. The Court said that "if the punishment prescribed for an offense against the laws of the State were manifestly cruel and unusual as burning at the stake, crucifixion, breaking on the wheel, or the like, it would