-Caveat Lector-

 The following article was printed in 1957 from a speech made by a Yale Law
graduate.  Excerpt:  "Year after year, the pattern remained the same.
Addicts and small-fry peddlers 105 were arrested by the thousands;106 the
traffic prospered; and the overlords at the top of the illicit operations
never got near "the stuff" and were rarely brought to account.107 This
fantastic black market, where smuggled drugs brought thousands of times
their intrinsic value, remained an exclusively American phenomenon, playing
its part, along with bootlegging, in the rise of gangsters and the emergence
of bigtime organized crime."

The more things change, the more they stay the same, no?

Linda Minor



NARCOTIC DRUG LAWS AND ENFORCEMENT POLICIES

By

RUFUS KING

*A.B. 1938, Princeton University; LL.B. 1943, Yale University. Member of the
New York, Maryland, and District of Columbia bars. Chairman, Committee on
Narcotics and Alcohol, Section of Criminal Law, American Bar Association.
Counsel, Senate Crime Commission, 1951; Senate Committee on Crime and Law
Enforcement in the District of Columbia, 1953. Contributor to legal
periodicals.

Reprinted from the symposium on

NARCOTICS

Published as the Winter, 1957, issue of

LAW AND CONTEMPORARY PROBLEMS

Duke University School of Law

Durham, N. C.



The King's argument was that anything that had a head could be beheaded, and
that you weren't to talk nonsense.

The Queen's argument was that ' if something wasn't done about it in less
than no time, she'd have everybody executed, all round. . . .

Lewis Carroll, Alice's Adventures in Wonderland

Repressing the narcotic drug traffic by criminal sanctions is a
comparatively recent innovation in the United States. Addicted persons have
enjoyed the appellation "dope fiend" for only some forty years,1 while the
"pusher" of pre-World-War-I society was usually the local pharmacist,
grocer, confectioner, or general-store-keeper.2 In fact, until the turn of
the twentieth century, the use of opium and its derivatives was generally
less offensive to Anglo-American public morals than the smoking of
cigarettes.3

In many significant features, the patterns we have evolved to deal with this
problem are atypical. First, the problem itself is viewed by most other
civilized nations as one involving health rather than criminality, and it is
virtually nonexistent in the view and experience of some. Moreover, although
the ingestion and injection of narcotic substances seem patently to be
matters primarily of local concern, the federal government has innovated our
repressive policies, almost sua sponte, and a federal agency has been the
dominant enforcement instrument from the very outset; even the initial
impetus came, in part at least, from a treaty commitment undertaken by the
federal government-far removed from considerations of state police power or
local public policy. Furthermore, Congress has never, before or since relied
upon the federal tax laws to achieve an objective so remotely connected with
the collection of revenues,4 and no comparable law-enforcement assignment
(disregarding the troublesomely analogous Prohibition experiment) has ever
been given to the Treasury Department.

Most notably unusual, however, this chronicle of federal intervention is an
epoch of dismal failure. Congress has expanded the list of federal crimes in
support of local enforcement efforts a dozen times in the last half century,
and with no other exception (again, omitting the Volstead Act), the results
have been salutary: federal intervention has caused the problem to diminish
or disappear.5 But this has not been true of the illicit drug traffic: the
costs of drug-law enforcement have increased steadily, 6 and though
estimates of our addict population are manipulatable in a wide range, no one
suggests that addiction has ever shrunk to negligible proportions or ceased
to be widespread.7 An addict cut off from his supply for a few days "kicks
the habit"; so the mere survival of this substantial community of "users"
over the years over forty years-is unanswerable proof that illicit
traffickers have never been deterred from meeting the addict's needs.8

The United States adhered to the Hague Opium Convention of 1912, by which it
undertook to control the domestic production, sale, use, and transfer of
opium and coca products.9 Since, however, neither opium poppies nor coca
shrubs were being grown extensively in this country, our undertaking to curb
production was a mere formality, apparently agreed upon to encourage
countries which were producers to join in restricting supplies in the world
market.10 There was, of course, perfect logic in our pursuit of this aim: if
we could have induced all nations where raw drugs might be grown to clamp on
tight controls, our domestic traffic, dependent on smuggling, would long
since have disappeared. We have remained staunch in our support of
international action to control supplies, adhering to subsequent
conventions,11 and working diligently through the League of Nations, the
United Nations, and the autonomous Permanent Central Opium Board.12 Most
recently, we have been promoting the idea of an International Opium
Monopoly, with plenary powers of inspection and control.13

But American efforts to induce other nations to forego the production and
marketing of drugs, so as to rid us of the illicit importer, have never
borne much fruit.14 Our friends have been apathetic,15 and our cold-war
enemies have been flatly uncooperative.16 Excepting the duration of World
War II, when many opium-producing countries were cut off and travel
restrictions put most smugglers out of business, narcotic drugs have
continued to flow freely into our illicit market.17

Amore significant aftermath of our participation in the 1912 convention was
the Harrison Act,18 passed by the Sixty-third Congress principally to comply
with our undertaking to control the domestic sale, use, and transfer of
opium and coca products.19 This act has provided the basis for domestic law
enforcement, vis-a'-vis the illicit drug traffic, ever since its enactment.
As has been observed, it is not a forthright criminal statute, but rather a
regulatory measure in the ill-tailored guise of a federal revenue enactment.
It must be remembered that, except for smoking opium, which had long been
contraband 21 there were no effective controls on any part of the traffic in
drugs prior to 1914.22 Addicted persons who sought comfort or intoxication
could buy whatever they wanted from any supplier, at moderate prices;23 and
those who wished to avail themselves of medical care could apply to any
member of the profession 24 for any indicated treatment, including gradual
withdrawal or even a permanent "comfort" regime.25 On its face, therefore,
the Harrison Act seemed better designed to bring the traffic into observable
and controllable channels26 than to repress all nonmedical uses by
transforming a large group of hitherto law abiding citizens into felons.

The heart of the act is an excise tax, imposed at the rate of one cent per
ounce27 on opium, isonipecaine, coca leaves, and other opiates and their
derivatives,28 to be evidenced by stamps affixed to the package or container
and payable by the importer, manufacturer, producer, or compounder-i.e., the
first domestic handler. Other provisions operate, in theory, at least, to
facilitate the collection of this not-too-exorbitant impost. Thus, it is
unlawful for anyone to purchase, sell, dispense, or distribute any narcotic
drugs, unless he does so in or from the original stamped package.29 It is
also unlawful for anyone to sell, barter, exchange, or give away such drugs,
except pursuant to a written order from the recipient, prepared on special
forms supplied by the Treasury Department.30

Persons in any vocation involving the handling of narcotic drugs-eg.,
importers, manufacturers, wholesalers, pharmacists, doctors, dentists,
researchers, etc.-also are required to register with the Treasury Department
and pay an occupational tax graduated from one to twenty-four dollars.31
Registrants are required to keep records, available at all times for
inspection by law-enforcement officers, and to file returns as required by
the Secretary of the Treasury.32

In 1937, marijuana was subjected to a similar pattern of control,33 except
that the tax rate was prohibitory-one dollar per ounce on any transfer of
marijuana to any person registered under the provisions of the act, and one
hundred dollars per ounce on any transfer to an unregistered person. 34

It will readily be observed that this pattern provides the strictest kind of
controls for the so-called legitimate traffic in drugs-i.e., for whatever
supplies are permitted to pass through the regulated channels, covered by
the Harrison Act. The registration and return provisions assure that all
legitimate traffickers are known to the authorities, while the revenue
stamps, the official transfer forms, and the records required to be kept at
each stage bring each individual transaction into plain view for official
scrutiny. Moreover, to facilitate enforcement, the complexity of this
pattern has been exploited to multiply penalties and sanctions: besides the
general tax-law provisions which punish evasion-failure to file returns,
fraud, counterfeiting of stamps, and the like35 -the mere possession of
drugs in unstamped containers is "prima facie evidence of a violation"36
drugs in unstamped containers are subject to seizure and forfeiture;37 any
act requiring registration-ie., any "trafficking" without registering-is
made a separate offense, independent of the failure to register per se;38
and the act of transporting drugs is a crime for any person not registered
or protected by certain specific exemptions-e.g., common carriers, employees
of registrants, public officials acting in the scope of their duties, etc.39

During its entire four decades, the Harrison Act has been an unqualified
success as a strictly regulatory measure.40  Its weaknesses and failures
show up only in its repressive applications, where it has been sweepingly
invoked as a prohibition enactment.41 By diligent police work, the
authorities have seen to it that narcotic drugs, once lawfully imported and
consigned to registered distributors and dispensers, rarely go astray, even
in minute quantities; but they have never been able to cope with the
enormous flow of smuggled drugs that are distributed to addict-consumers
without ever entering the regulated channels at all.42

Perhaps these forty years of failure have also been forty years of error.
There is authority-including emphatic support from the courts-for the
proposition that addicts were never intended to be pushed outside the
regulatory framework, as Congress envisaged it in passing the act.43 They
might, as reasonably, have been expected, instead, to address themselves to
the medical profession for help.44 The statutory language is susceptible of
differing interpretations as to its effects on medical practitioners, and
this is what has led to uncertainty as to its prohibitory scope. If it be
conceded that all supplying of drugs to addict-consumers-i.e., uncontrolled
sales by unlicensed and unregistered persons-was to be ended, there yet
remained the question whether doctors might not take care of their
addict-patients by prescribing or administering as the doctors deemed
necessary.

Physicians, dentists, and veterinary surgeons45 who are "lawfully entitled"
to dispense drugs46 must register47 and keep records,48 but they may
prescribe or administer drugs without making use of the written Treasury
Department order form,49 and without regard for the original-stamped-package
requirement.50 And persons possessing drugs obtained pursuant to a
prescription, or received directly from a registered practitioner, are
excepted from the general prohibitions against transportation51 and
possession.52 But difficulty arises from the fact that every one of these
exemptions and exceptions is qualified with language that implies additional
limitation. Thus, the prescription specified exempts the recipient only if
it is "issued for legitimate medical uses. . . ."53 And the direct
dispensing similarly exempted is covered only when it is "to a patient by a
registered physician ... in the course of his professional practice," and
where said drugs are dispensed or administered to the patient "for
legitimate medical purposes. . . ."54 Similarly, the language which excuses
medical practitioners from the order-form requirement covers dispensing "to
a patient by a physician in the course of his professional practice only . .
. "55, and makes it expressly unlawful for any person, including
practitioners, to obtain drugs "for any purpose other than the use, sale, or
distribution thereof by him . . ." in the legitimate practice of his
profession.56 Even the exemptions which permit interstate transportation of
drugs by persons who have received them on prescription or by direct
dispensation from a physician specify that the prescription must have been
"issued for legitimate medical uses" and the dispensation must have been "to
the patient for legitimate medical purposes."57 The parallel exemption
permitting possession by unregistered persons uses different phrasing: the
drug must have been "prescribed in good faith."58 And the Marihuana Act
contains similarly qualified exemptions for transfers by a registered
medical practitioner "in the course of his professional practice only" and
by a pharmacist if "made in good faith" in pursuance of a prescription.59

What did the lawmakers intend when they selected all these qualifying
phrases? Who was to decide what constituted "legitimate medical purposes,"
set the bounds of "professional practice only," pass on the practitioner's
"good faith," and determine whether he had departed from "the legitimate
practice of his profession"? At the outset, the questions were not sharply
put.60' The nation was absorbed in World War I, and the Treasury Department
seemed content to let the new regulatory pattern emerge slowly. But in 1919,
the lull ended, and a veritable blitz commenced. A special Treasury
Department committee stunned the nation with a report that one million perso
ns had become addicted to "dope," mostly young people, many "under the age
of 20."61 And in 1920, the Narcotics Division of the Treasury Department was
merged into the lusty new Prohibition Unit, then launching its roistering
crusade against liquor-drinkers and bootleggers.62

The first point of attack was necessarily the medical profession. While
reputable doctors accepted the addict's affliction as one within the purview
of the Hippocratic Oath, there could be no wholesale roundups and
headline-making arrest records-nor, incidentally, could the sinister "dope
ring" of later chronicles make its appearance.63 If the addict remained a
"patient" he could bargain for help, albeit on rigorous terms, with those
who understood his problem and could aid him most-and no sacrifice in the
cause of therapy could have approached the cruel enslavement that was to
follow later, when his only bargain was with the illicit peddler, on the
latter's terms. Medical men were aware of this responsibility, and, by and
large, they were responsive to it, until the early twenties. Then, they were
driven into full retreat by a series of Supreme Court decisions that still
record one of the most astonishing occurrences in our legal history. The
High Court was the victim of a trick.

On the same day on which the constitutionality of the Harrison Act was
affirmed,64 the Court handed down the first of the "doctor" cases, Webb v.
United States, in which the Government had posed the following certified
question:65

If a practicing and registered physician issues an order for morphine to an
habitual user thereof, the order not being issued by him in the course of
professional treatment in the attempted cure of the habit, but being issued
for the purpose of providing the user with morphine sufficient to keep him
comfortable by maintaining his customary use, is such order a physician's
prescription under exception (b) of  s2? 66

And the justices responded:67

[T]o call such order for the use of morphine a physician's prescription
would be so plain a perversion of meaning that no discussion of the subject
is required.

Two extraneous facts doubtless influenced the Court's response: at this time
(1919), public hysteria about the "dope menace" was thoroughly whipped up;
and the case was one of flagrant abuse (Dr. Webb had sold prescriptions by
the thousands, indiscriminately to any applicant, for fifty cents apiece).68

The second case, Jin Fuey Moy v. United States69 also arose out of an
outrageous set of facts: the doctor had written prescriptions for morphine
by the gram, for all comers, at one dollar per gram. The Court sustained his
conviction, holding:70

Manifestly the phrases "to a patient" and "in the course of his professional
practice only" are intended to confine the immunity of a registered
physician, in dispensing the narcotic drugs mentioned in the act, strictly
within the appropriate bounds of a physician's professional practice, and
not to extend it to include a sale to a dealer or a distribution intended to
cater to the appetite or satisfy the craving of one addicted to the use of
the drug.

Next came the case that contained the joker, United States v. Behrman,
decided March 27, 1922.71 Here, too, the abuse was flagrant. Dr. Behrman had
given a known addict, at one time and for use as the addict saw fit,
prescriptions for 150 grains of heroin, 360 grams of morphine, and 210 grams
of cocaine. But the indictment was drawn so as to omit any accusation of bad
faith; it charged, in effect, that this treatment was for the purpose of
curing the addict,72 and, thus, its validity depended on a holding that
prescribing drugs for an addict was a crime, regardless of the physician's
intent in the matter. The District Court sustained a demurrer, and the
Government invoked its right to appeal directly to the Supreme Court.73

A majority of the justices, no doubt moved by the flagrant facts, which they
set forth fully in the opinion,74 ruled that the indictment was good. Three
dissented tersely: 75

It seems to me wrong to construe the statute as creating a crime in this way
without a word of warning. Of course the facts alleged suggest an indictment
in a different form, but the Government preferred to trust to a strained
interpretation of the law rather than to the finding of a jury upon the
facts. I think that the judgment should be affirmed.

The dissenters, besides Holmes, who wrote for them, were justices Brandeis
and McReynolds.

Armed with what came to be known as the Behrman indictment, the Narcotics
Division launched a reign of terror. Doctors were bullied and threatened,
and those who were adamant went to prison.76 Any prescribing for an addict,
unless he had some other ailment that called for narcotization, was likely
to mean trouble with the Treasury agents. The addict-patient vanished; the
addict-criminal emerged in his place. Instead of policing a small domain of
petty stamp-tax chisellers, the Narcotics Division expanded its activities
until it was swelling our prison population with thousands of felony
convictions each year.77 Many of those who were caught had been respected
members of their communities until the T-men packed them off.78

In short order, however, the Behrman ruling found a challenger. Dr. Charles
0. Linder, after a lifetime of honorable practice in Spokane, Washington,
was induced by one of the Division's odious addict-stool-pigeons to write a
prescription for four small tablets of cocaine and morphine.79 Several
agents thereupon descended on his office, conducted a rowdy search, and
dragged him off to jail.80 He was indicted in the Behrman form, convicted,
sentenced, and lost on his appeal to the Circuit Court of Appeals.81 But he
carried the fight on to the Supreme Court, where he was completely
vindicated.82 The opinion, unanimous this time and written by justice
McReynolds, set forth what is still the controlling interpretation of the
Harrison Act :83

The enactment under consideration levies a tax, upheld by this court, upon
every person who imports, manufactures, produces, compounds, sells, deals
in, dispenses or gives away opium or coca leaves or derivatives therefrom,
and may regulate medical practice in the States only so far as reasonably
appropriate for or merely incidental to its enforcement. It says nothing of
"addicts" and does not undertake to prescribe methods for their medical
treatment. They are diseased and proper subjects for such treatment, and we
cannot possibly conclude that a physician acted improperly or unwisely or
for other than medical purpose solely because he has dispensed to one of
them, in the ordinary course and in good faith, four small tablets of
morphine or cocaine for relief of conditions incident to addiction.

The Court warned that its opinions in the Webb and Jin Fuey Moy cases should
be narrowly limited to the facts there involved, and then it dismissed the
Behrman case (and blasted at the Behrman indictment) in the following strong
disclaimer :84

This opinion related to definitely alleged facts and must be so understood.
. . . The opinion cannot be accepted as authority for holding that a
physician who acts bona fide and according to fair medical standards, may
never give an addict moderate amounts of drugs for self-administration in
order to relieve conditions incident to addiction. Enforcement of the tax
demands no such drastic rule, and if the Act had such scope it would
certainly encounter grave constitutional difficulties.

But by 1925, it was too late to change the pattern. The trick had worked.
The doctors had withdrawn, and they never permitted the addict to reapproach
them.85  The peddler had taken over, and his profits soared as enforcement
efforts reduced his competition and drove his customers ever deeper into the
underworld, where they were easy prey. It is significant that the
present-day regulation of the Narcotics Bureau advising doctors of their
rights in dealing with addicts blithely ignores what the Supreme Court said
in the Linder case86 and still paraphrases the discredited language of Webb
v. United States:87

An order purporting to be a prescription issued to an addict or habitual
user of narcotics, not in the course of professional treatment but for the
purpose of providing the user with narcotics sufficient to keep him
comfortable by maintaining his customary use, is not a prescription within
the meaning or intent of the Act; and the person filling such an order, as
well as the person issuing it, may be charged with violation of the law.

Simultaneously with its campaign to cut the addict off from recourse to
medical help, the Narcotics Division launched an attack on him along another
line as well. He was portrayed as a moral degenerate, a criminal type, and
the public was told that he could only be dealt with by being isolated from
all normal contacts with society; if left at large, one of his main
preoccupations was allegedly contriving ways to induce others to share his
misery by becoming addicted themselves. In short, he should be caught and
locked up.88 A formal action taken by the American Medical Association in
1924 is still cited as official concurrence by the doctors in this
viewpoint.89 But it is more likely that here, also, the zeal of the
enforcement authorities led them to overstretch the limits of reasonable
interpretation.

At its annual meeting in 1919, the House of Delegates of the American
Medical Association had passed two resolutions, one calling on the
Commissioner of Internal Revenue to organize a nation-wide conference "with
a view to controlling the traffic in and harmful consumption of narcotic
drugs," and the other creating a special four-man committee to study the
entire situation and report back to the House.90 The latter committee
reported the following year, recommending, inter alia, that heroin be
totally eliminated from all medical preparations and use, and that "the
ambulatory treatment of drug addiction . . . be emphatically condemned."91
The committee was referring to the prescribing of drugs to addicts for
self-administration at the addict's convenience and out of the doctor's
supervisory control. The word "ambulatory," however, also implied being
physically at liberty instead of hospitalized or imprisoned. The text
adopted by the 1924 resolution was:92

Your committee desires to place on record its firm conviction that any
method of treatment for narcotic drug addiction, whether private,
institutional, official or governmental, which permits the addicted person
to dose himself with the habit-forming narcotic drugs placed in his hands
for self-administration, is an unsatisfactory treatment of addiction, begets
deception, extends the abuse of habit-forming narcotic drugs, and causes an
increase in crime. Therefore your committee recommends that the American
Medical Association urge both federal and state governments to exert their
full powers and authority to put an end to all manner of such so-called
ambulatory methods of treatment of narcotic drug addiction, whether
practiced by the private physician or by the so-called "narcotic clinic" or
dispensary.

In the opinion of your committee, the only proper and scientific method of
treating narcotic drug addiction is under such conditions of control of both
the addict and the drug, that any administration of a habit-forming narcotic
drug must be by, or under the direct personal authority of the physician,
with no chance of any distribution of the drug of addiction to others, or
opportunity for the same person to procure any of the drug from any source
other than from the physician directly responsible for the addict's
treatment.

The doctors, thus, were saying that the administering and dispensing of
drugs ought to be strictly controlled by themselves. The authorities,
however, twisted this to mean that addicts undergoing treatment ought to be
strictly controlled by the authorities-i.e, incarcerated.93

The reference to "narcotic clinic" in the last quotation requires
explanation. Between 1912 and 1923, a substantial number of medical men and
public health officials tried to counter the assaults being made on narcotic
addicts by the establishment of private or public-sponsored narcotics
dispensaries. These varied widely in the details of their operation and the
quality of their programs, but their aim was to provide a controlled supply
for addicts who suddenly found themselves cut off by the new federal statute
and the Treasury Department's vigorous enforcement campaign. In some
instances, the clinic personnel tried to rehabilitate applicants and effect
cures; but the main emphasis was on meeting the immediate needs of addicted
persons who would otherwise be driven into the developing illicit market or
end up in prison. Such institutions were opened in some forty cities
throughout the country, 94 and some, at least, were acknowledged by
contemporary observers to be successful,95 though it is charged that some
quickly degenerated into simple peddling operations, distributing drugs
haphazardly to all applicants.

The clinic experiments, good and bad alike, came to an abrupt end in the
early 1920's, however, when Treasury agents closed on them, threatening
federal prosecutions.96 Many details of these experiments and their history
are now obscured. Treasury spokesmen, echoed by United States Public Health
Service officers, have missed no opportunity to attack the clinic concept as
impracticable, immoral, and downright subversive.97 Since 1923, there has
been no attempt to revive any public facility for the treatment of addicts
on an out-patient basis. The federal hospitals at Lexington, Kentucky, and
Fort Worth, Texas, authorized in 1929,98 are admirable centers for
withdrawal and rehabilitation of federal-prisoner addicts and those who
submit voluntarily for treatment; but both are dedicated to the principal of
absolute isolation as a sine qua non of therapy?99

In the early thirties, a doctor in Seattle opened a private clinic to
furnish narcotic drugs to addicts. He observed the crucial distinction
between direct administration to each patient, and prescribing or dispensing
in quantity so that the drugs might be overindulged or resold; he
administered directly only. But he promptly attracted the attention of the
Narcotics Bureau. He was first indicted in May 1934 and was acquitted after
a full jury trial.100 Thereafter, he continued his operations under the
hostile surveillance of Narcotics Bureau agents, who made a second case
against him, resulting in another indictment, in November 1935. This time,
he was convicted, sentenced to seven years, and fined $10,000. Subsequently,
pending his appeal, which resulted in affirmance,101 he gave bond and sought
to continue his clinic operation. The Narcotics Bureau countered,102
however, by ordering his wholesale suppliers to refrain from selling
narcotic drugs to him. He brought an action in the District of Columbia
courts, to enjoin the Commissioner from thus interfering with his
activities-and it was only when he lost the first round of this collateral
skirmish, being denied a temporary restraining order,103 that he gave up the
fight. He went to the McNeil Island Penitentiary in June 1937, and in 1938,
the State of Washington Department of Licenses revoked his medical license
.104

Year after year, the pattern remained the same. Addicts and small-fry
peddlers 105 were arrested by the thousands;106 the traffic prospered; and
the overlords at the top of the illicit operations never got near "the
stuff" and were rarely brought to account.107 This fantastic black market,
where smuggled drugs brought thousands of times their intrinsic value,
remained an exclusively American phenomenon, playing its part, along with
bootlegging, in the rise of gangsters and the emergence of bigtime organized
crime.

In 1951, the Kefauver Committee turned its attention to narcotics and
marijuana, 108 causing a flurry of public apprehension. It was alleged that
drug addiction was on the increase and had captured school children and
teen-agers.109 In this atmosphere, the Narcotics Bureau announced that
stiffer penalties, harsher repression, and more law-enforcement efforts were
the answer.110 Dozens of "tough" measures were introduced in the
Eighty-first Congress by lawmakers vying for public approbation as saviors
in the face of this exaggerated menace.111

The bill which eventually became law was the offering of Congressman Hale
Boggs, of Louisiana. Its chief feature was mandatory minimum sentences,
applicable to all narcotic drug offenses, and graduated as follows: first
conviction, two to five years; second, five to ten years; and third, ten to
twenty years.112 For second and subsequent offenses, the judge was
prohibited from suspending the sentence or granting probation. This measure
was opposed by the American Bar Association,113 and it has reportedly been
ignored or defied by sentencing judges in a significant number of cases
where the defendants before them seemed to merit less than the prescribed
minimum punishment. But the popularity of vindictive attitudes towards
anyone related to the "dope menace" evoked responses in state legislatures
as well, and a number of jurisdictions have emerged with "little Boggs
Acts."114

In the same wave of popular interest, new legislation was enacted in a
number of jurisdictions providing for the compulsory treatment-in
confinement-of addicts.115   Addiction has been made a crime per se in
several states.116 In nearly every instance, however, the result has been
merely to provide another statutory weapon for use against addicts,
permitting apprehension and imprisonment without the formality of making a
case on possession or sale.117

In February, 1955, the House of Delegates of the American Bar Association
passed a resolution urging Congress "to undertake a re-examination of the
Harrison Act, its amendments, and related enforcement and treatment policies
and problems.118  On March 18, 1955, the Senate adopted S. Res. 67, which
authorized a subcommittee of the Senate Judiciary Committee to make such a
study. This subcommittee, under the chairmanship of Senator Daniel, toured
the country, hearing hundreds of witnesses and amassing thousands of pages
of testimony.119  Enforcement officers attorneys general, states' attorneys,
sheriffs, and police chiefs in some 2500 communities-were also canvassed by
questionnaire.

The subcommittee's conclusions were submitted in a nine-page document120
that reached two general conclusions: federal laws should be tougher, and
the Narcotics Bureau should have larger appropriations. Among its specific
findings were pronouncements that the current addict-population of the
United States is "more . . . than all of the other western nations
combined"; that thirteen per cent of this group are under twenty-one years
of age; that the illicit traffic has trebled since World War II; 121 that
drug addiction is responsible for fifty percent of all crime in urban areas
and twenty-five per cent of the nation's total reported crimes; 122 and that
drug addiction is "contagious"-i.e., addicts spread addiction "with
cancerous rapidity." The subcommittee also avowed that "subversion through
drug addiction is an established aim of Communist China," and that the
United States is, thus, "one of the principal targets" of a communist plot
"to demoralize susceptible individuals in our services and in the general
population."123

On the question of treatment for addicted persons, the subcommittee
concluded that such persons should first be "removed from society"; and if
treatment fails, they must be permanently consigned to "a quarantine type of
confinement or isolation ."124 In a second report,125 the subcommittee
blasted what it termed "the so-called clinic plan for legal distribution of
narcotics [to drug addicts],126 opining that the plan "is totally
unworkable, completely contrary to accepted medical practice and theory, and
would aggravate rather than solve the problem. . . ." Its arguments included
the familiar assault on "ambulatory" treatment, coupled with the assertion
that no treatment could be effective without "hospitalization or other
confinement"; that physical administration of drugs would be impracticable
because of the need for frequent injections, plus the mounting "tolerance"
factor; that clinics would merely supplement, not supplant, the illicit
market as a source for their addict clientele; and that legalizing any
distributions would create new addicts, because addiction "has the
contagious qualities of a social disease." Any such plan would also be "in
absolute contradiction" to our national obligations under various treaty
commitments, would conflict with state laws, and would, in sum, be "a
complete turnabout in our present policies and programs." Finally, to clinch
the argument, the subcommittee affirmed its belief "that it would be
absolutely immoral to give in to drug addiction and help perpetuate such
pitiful conditions for the individual human being."127

The subcommittee offered a number of legislative proposals, which became law
without significant opposition in the last days of the 84th Congress.128
Without further distinguishing addicts from traffickers, the new laws raise
the assessable fine for all narcotics offenses to $20,000 129 and increase
the mandatory minimum sentences to two, five, and ten years for successive
offenses in the possession, prescription, and registration categories,"130
while first sale, transfer, and smuggling offenses carry a minimum sentence
of five years, which increases to ten years for all succeeding offenses."131
Special penalties apply to any sale or transfer by an adult132... to a
person under eighteen: for any such offense, the minimum sentence is ten
years; and if the drug is heroin, the court may impose life imprisonment or
the jury may direct the imposition of a sentence of death.133

The new law directly outlaws heroin 134 and contains a miscellany of special
provisions to make the police work of the Narcotics Bureau easier. Customs
and Narcotics Bureau agents may carry arms and may make arrests without a
warrant on belief that a drug-law offense has been committed.135

Search warrants issued in connection with alleged narcotics offenses may be
served at night under certain circumstances.136 In narcotics cases, unlike
other federal prosecutions, the Government may appeal from pretrial orders
suppressing evidence, 137 while testimony may be compelled from witnesses,
despite the plea of self-incrimination, by means of a special immunity
grant.138 Drug users and drug-law offenders are required, fatuously perhaps,
to disclose themselves, register, and obtain a special certificate upon
entering or departing from the United States139 (in peril of a penalty
provision that is anything but fatuous, however: one thousand dollar fine
and minimum one-year sentence). Drug addiction and drug-law violation are
made grounds for deportation under the Immigration and Nationality Act.140
And to add the ultimate compounding of penalties, the new law creates a
separate category of offenses (minimum two-year sentence and five thousand
dollar fine) based on the use of communication facilities "in committing or
in causing or facilitating the commission of, or in attempting to commit"
any drug-law offense; communication facilities include "any and all public
and private instrumentalities used or useful in the transmission of
writings, signs, signals, pictures, and sounds of all kinds by mail,
telephone, wire, radio, or other means of communication"; and "each separate
use of a communication facility shall be a separate offense. . . .141

The Daniel subcommittee epitomized its philosophy, and synthesized the
prevailing attitude of today's lawmakers and law enforcers, in the
concluding paragraph of its report on the care of addicts:...142

It should be noted that these recommendations for treatment and
rehabilitation are not intended as a substitute for criminal confinement and
punishment of those addicts who are convicted of law violations. They should
pay their debt to society the same as non-addicts, and proper law
enforcement and confinement in such instances will do much towards
minimizing the narcotics traffic and addiction in the United States.

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