drug abuse

Alfred Smith and Galen Black were members of the Native American Church employed at a private drug rehabilitation organization in Oregon. They ingested peyote for sacramental purposes during a church ceremony. Their employer fired them for this conduct, treating it as work-related misconduct. Smith and Black applied to the Employment Division of the Oregon Department of Human Resources for unemployment compensation benefits, but the Division denied the claims on the ground that the firings constituted misconduct. The Oregon Court of Appeals reversed the denials, holding that they violated the respondents' free exercise rights under the First Amendment. The Oregon Supreme Court concluded that respondents were entitled to payment of unemployment benefits. The U.S. Supreme Court granted certiorari, vacated the judgment, and remanded for a determination whether Oregon law prohibited the sacramental use of peyote. On remand, the Oregon Supreme Court held that the statute made no exception for sacramental use and reaffirmed its conclusion that denying benefits violated the respondents' constitutional rights. The U.S. Supreme Court granted certiorari a second time. Oregon law prohibits knowing or intentional possession of peyote, a Schedule I controlled substance, making it a Class B felony. The respondents' peyote use occurred at a Native American Church ceremony and formed the sole basis for their terminations and benefit denials.

The Federal Railroad Safety Act of 1970 authorizes the Secretary of Transportation to prescribe rules for railroad safety. For many years, railroads have enforced Rule G prohibiting operating employees from possessing alcohol or being intoxicated while on duty. In July 1983, the Federal Railroad Administration expressed concern that these efforts were inadequate after identifying at least 21 significant train accidents from 1972 to 1983 involving alcohol or drug use as a probable cause or contributing factor. After soliciting comments and announcing its intention in June 1984, the FRA promulgated regulations in 1985. Subpart C mandates that railroads transport covered employees to medical facilities for blood and urine testing after major train accidents, impact accidents, or incidents involving a fatality to an on-duty employee. Subpart D authorizes railroads to require breath or urine tests after reportable accidents where a supervisor has reasonable suspicion or upon specified rule violations. The Railway Labor Executives' Association and member labor organizations sued in the Northern District of California seeking to enjoin the regulations. The district court granted summary judgment to the Secretary of Transportation and the FRA. A divided panel of the Ninth Circuit reversed. The Supreme Court granted certiorari.

In November 1999, fourteen-year-old Kuntrell Jackson and two other boys decided to rob a video store in Arkansas. En route, Jackson learned that one of the boys carried a sawed-off shotgun. Jackson initially stayed outside the store but later entered while the robbery was underway. When the clerk, Laurie Troup, refused to hand over money and threatened to call the police, one of Jackson's co-defendants shot and killed her. The three boys fled without taking any money. Arkansas prosecutors exercised their discretion to charge Jackson as an adult with capital felony murder and aggravated robbery. A jury convicted him of both offenses. The trial court imposed the statutorily mandated sentence of life imprisonment without the possibility of parole. Jackson did not challenge the sentence on direct appeal, and the Arkansas Supreme Court affirmed the convictions. In 2003, fourteen-year-old Evan Miller and a friend, Colby Smith, spent an evening drinking alcohol and smoking marijuana with Miller's neighbor, Cole Cannon, at Cannon's trailer in Alabama. After Cannon passed out, Miller stole his wallet. Cannon awoke and grabbed Miller by the throat. Smith struck Cannon with a baseball bat, and Miller then repeatedly hit Cannon with the bat. The boys set two fires in the trailer before leaving. Cannon died from his injuries and smoke inhalation. Miller had previously been in and out of foster care, regularly used drugs and alcohol, and had attempted suicide four times. Alabama law initially required that Miller be charged as a juvenile, but the district attorney sought and obtained removal of the case to adult court. A jury convicted Miller of murder in the course of arson. The trial court imposed the statutorily mandated sentence of life imprisonment without the possibility of parole. The Alabama Court of Criminal Appeals affirmed the conviction and sentence. Following this Court's decisions in Roper v. Simmons and Graham v. Florida, Jackson filed a state habeas petition arguing that his mandatory life-without-parole sentence violated the Eighth Amendment. The circuit court dismissed the petition, and the Arkansas Supreme Court affirmed. Miller's direct appeal was likewise unsuccessful. The Supreme Court granted certiorari in both cases.

Ronald Harmelin was convicted in Michigan state court of possessing 672 grams of cocaine. Michigan law imposed a mandatory sentence of life imprisonment without possibility of parole for that quantity of the drug. Harmelin had no prior felony convictions. The Michigan Court of Appeals initially reversed the conviction because evidence supporting it had been obtained in violation of the Michigan Constitution. On petition for rehearing, the Court of Appeals vacated its prior decision and affirmed the sentence. The Michigan Supreme Court denied leave to appeal. The United States Supreme Court granted certiorari. The quantity of cocaine at issue had a potential yield of between 32,500 and 65,000 doses. The sentencing court imposed the mandatory term without considering any individualized circumstances of the offense or the offender. Harmelin challenged the sentence on Eighth Amendment grounds, arguing both that it was grossly disproportionate to the crime and that the mandatory nature of the penalty was unconstitutional.

In 1996 California voters enacted the Compassionate Use Act authorizing limited marijuana use for medicinal purposes by seriously ill state residents upon a physician’s recommendation or approval. Angel Raich and Diane Monson, California residents suffering from serious medical conditions, began using marijuana after their licensed physicians determined that conventional medicines failed to provide relief and that marijuana was the only effective treatment available. Raich, unable to cultivate her own supply, relies on two caregivers who grow and provide locally grown marijuana at no charge, which she then processes into oils, balms, and foods. Monson cultivates her own marijuana plants and ingests the drug by smoking or vaporization. On August 15, 2002, county deputy sheriffs and federal Drug Enforcement Administration agents arrived at Monson’s home. County officials concluded after investigation that Monson’s use complied with California law, but after a three-hour standoff the federal agents seized and destroyed all six of her cannabis plants. Raich and Monson filed suit in the United States District Court for the Northern District of California against the Attorney General of the United States and the Administrator of the DEA. They sought injunctive and declaratory relief barring enforcement of the federal Controlled Substances Act to the extent it prevented them from possessing, obtaining, or manufacturing cannabis for personal medical use, and they submitted affidavits describing their medical conditions, failed conventional treatments, and physicians’ recommendations. The district court denied the motion for a preliminary injunction. A divided panel of the Court of Appeals for the Ninth Circuit reversed and ordered the district court to enter the injunction. The Supreme Court granted certiorari.