Substantive Due Process And Criminal Law Limitations
What is Substantive Due Process?
Rooted in the Due Process Clause of the 14th Amendment.
Ensures laws are fair, reasonable, and just—not arbitrary or oppressive.
Protects fundamental rights, even from properly enacted laws.
In criminal law, limits what acts the government can criminalize or punish.
Key Cases on Substantive Due Process & Criminal Law
1. Powell v. Texas (1968)
Facts:
Powell was convicted for public intoxication, but argued alcoholism was a disease, so punishing him violated substantive due process.
Holding:
Court upheld the conviction, saying the state can criminalize public drunkenness despite alcoholism.
Significance:
Limits on substantive due process—states can regulate behavior that threatens public order even if related to a medical condition.
2. Robinson v. California (1962)
Facts:
Robinson was convicted for being addicted to narcotics, simply based on his status, not an act.
Holding:
Supreme Court ruled this violated the 8th Amendment cruel and unusual punishment and the 14th Amendment’s substantive due process.
Significance:
Punishing a person for status alone (addiction) violates substantive due process.
3. Lawrence v. Texas (2003)
Facts:
Texas criminalized consensual homosexual conduct; Lawrence challenged this as unconstitutional.
Holding:
Supreme Court struck down the law, holding it violated substantive due process rights to privacy and liberty.
Significance:
Expanded substantive due process protections to intimate personal decisions.
4. United States v. Bajakajian (1998)
Facts:
Bajakajian was fined $357,144 for failing to report transporting over $357,000 out of the country.
Holding:
Court ruled the fine was “grossly disproportionate” to the offense, violating the Excessive Fines Clause, part of substantive due process.
Significance:
Limits on excessive penalties as a substantive due process safeguard.
5. Chicago, Burlington & Quincy Railroad Co. v. Chicago (1897)
Facts:
Railroad company challenged a taking of property without just compensation.
Holding:
Court ruled that just compensation is required under substantive due process.
Significance:
Substantive due process includes protections against unfair deprivation of property.
6. United States v. Jones (2012) (relates to search & seizure but implicates substantive due process)
Facts:
GPS tracking of a suspect’s car without a warrant.
Holding:
Court ruled the warrantless GPS tracking violated the Fourth Amendment but raised substantive due process concerns about privacy.
Significance:
Modern interpretation of privacy rights and limits on government surveillance.
Summary Table
| Case | Issue | Holding | Significance |
|---|---|---|---|
| Powell v. Texas (1968) | Criminalizing public intoxication | Allowed conviction despite alcoholism | Limits on substantive due process |
| Robinson v. California (1962) | Punishing addiction as status | Unconstitutional punishment | Protects against punishment for status |
| Lawrence v. Texas (2003) | Criminalizing private conduct | Struck down sodomy law | Protects privacy & liberty rights |
| US v. Bajakajian (1998) | Excessive fines | Fine was grossly disproportionate | Limits excessive penalties |
| Chicago RR v. Chicago (1897) | Property deprivation without compensation | Just compensation required | Protects property rights |
| United States v. Jones (2012) | GPS tracking without warrant | Violates Fourth Amendment & privacy | Modern privacy protection |
Key Takeaways:
Substantive due process protects fundamental rights from arbitrary laws.
Criminal law must not punish status alone (e.g., addiction).
Laws criminalizing private, consensual conduct may be unconstitutional.
Excessive punishments can violate substantive due process.
Government actions must be reasonable and just, not arbitrary.
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