History of Legal and Medical Roles

in Narcotic Abuse in the U.S.

EARLE V. SIMRELL, A.M., LL.B.

WHEN the United States acceded to theUnited Nations' Single Convention on

Narcotic Drugs on May 25, 1967, it reinforcedthe trend toward greater involvement of bothgovernment and medicine in the problem ofnarcotic abuse. How government and medicinewill play their respective roles will continue tobe developed-and doubtless debated-but forneither is there any lessening of responsibilityin this international consensus (1).Our accession to the new convention, follow-

ing recent Federal, State, and local develop-ments, makes it timely to review the historicalpattern of action by government and medicineat these four levels in respect to narcotic abuseas a medical-social problem. Such history willnot determine what the roles should be, but it isimportant as background to what they are andwhat they may become.Contrary to some impressions, narcotic abuse

was recognized as a medical-social problem inthe United States long before the Harrison Actof 1914 (2). The problem had elements of ordi-nary vice, that is, a socially disapproved formof pleasure. It was also a medical problem,primarily that of self-medication with pain-killers for either physical or emotional pain,contrary to the judgment of ethical physicians.As a vice, narcotic abuse was largely identifiedwith opium smoking and opium dens, alien toAmerican concepts of legitimate pleasure.As a medical problem, addiction was preva-

lent among Civil War veterans who had beentreated with morphine. Medication with opiates

Mr. Simrell is special assistant to the director,Bureau of Health Services, Public Health Service.

was also commonly practiced-and vigorouslyencouraged by the patent medicine industry-for almost any ailment, including alcoholismand drug addiction. Physicians were enlisted inthe fight against nostrums and quackery. Sup-pression of vice and control of self-medicationcoalesced in legal controls against abuse of nar-cotic drugs (3).

State and local police measures were triedfirst, starting at least as early as 1885. A 1912study concluded that "there are few if any sub-jects regarding which legislation is in a morechaotic condition than the laws designed tominimize the drug-habit evil" (4). This studyquoted a report submitted in 1911 by the Presi-dent to Congress (5).The enormous misuse of opium and other habit-form-

ing drugs in the United States may be attributed toseveral causes-carelessness or ignorance on the partof the people; to ineffective State laws, as well as to theinability of States with good laws to protect themselvesagainst the clandestine introduction of the drugs fromneighboring or distant States, and therefore in alarger sense to the lack of control by the Federal Gov-ernment of the importation, manufacture, and inter-state traffic in theni.The U.S. Government had begun promoting

international action and taking its own meas-ures to control the world traffic in narcotics.President Theodore Roosevelt called an inter-national meeting at Shanghai in 1908 to initiatejoint action by interested governments (3). In1909 Congress passed "An Act to prohibit theimportation and use of opium for other thanmedicinal purposes." Congress did not define"medicinal purposes," but flatly excluded opi-um for smoking and subjected the importationof opium and opiates for medicinal purposes toregulation by the Secretary of the Treasury (6).

Vol. 83, No. 7, July 1968 587

The Hague Convention of 1912 establishedan international obligation to control domesticas well as foreign trade in opiates (7). TheHarrison Act of 1914 (2) completed the basicframework of legal controls-internationalcommitments, State aind local police measures,and Federa.l law to fulfill international com-mitments and reinforce State and local meas-ures. Government at all levels concentrated onlegal controls, in accord withl the contemporaryview of the role of government.

This multiple structure-initernationial, Fed-eral, State, and local-is still the basic frame-work of policy and action in the field of niarcoticabuse. At all jurisdictional levels there has beena growing emphasis on positive health. measures,but in combination witlh legal controls. There isa corresponding need for understaniding and ad-justment among jurisdictional levels and be-tween government and medicine.

International Action

It is perhaps symbolic that two of the threeU.S. plenipotentiaries at the 1912 Hague con-ference were a bishop and a physician (7). Theresulting, convention went, beyond control of in-ternational commerce and included obligationsto control manufact-ure, domestic traffie, aind useof opiates. A lonlg series of supplementary inter-national agreements followed and reinforcedthe Haguie Conv-ention of 1912 (8).The Ulnited Nations' single conventio()n is niow

supersedinig the 1912 convention andc most of itssuccessors (8). The niew convenitioni was aldoptedat a uniited Nations confereiica in 1961. TheIJnited States refuse(d to signi for fear that thecon-venitioni wouold weaken control of narcoticdrugs by perml-itting additionial countries to pro-duce opium anid by permitting goxver.nments toaccede wit.h reservationis. Bltt on MArch 8, 1967,President Johnson req(uested the Senate's adviceand consenit to accede for the Uniited States onthe grounds that tlle anticipated weakniesses hadnot proved serious and that accession w-ouldadvance our interest in drug control.The Senate Foreign Relations Committee

held hearings at wlhich tfhe Departments ofState and Treasury supported the newv conven-tioIn with extensive antalysis and documentation.No one appeared in opposition. The committeereported favorably on MaIly 3, 1967, the Senate

gave its advice and consent on May 8, and theformal accession with no reservations wasaccomplished AMay 25 (1, 8,9).The single convenition is a longr, complex, and

largely technical document. Although it has thefeatures wlhich the U.S. Government originallyconsidered as weakening, it continues essen-tially the previous international controls re-stricting the production, distribution, and use ofna,rcotic, drugs to medical and scientific pur-poses. It includes more obligations for accedinggoveriments, extenids the coverage of interna-tional commitments to more drugs, includingmarijuana and its raw materials, and providesfor adding new- drugs to the control lists. Someprov-isions are manddatory, some are recommen-dations, anid some are qualified by such clausesas "'if the Parties deem these measures necessaryor desirable." With all its flexibility, however,the convention represents a high degree of inter-national policymaking in domestic as well asiniternationial aspects of drug abuse.

It also combines legal controls with positivehealth measures. On one hand, subject to consti-tutional limitations, eaclh government is obli-gated to adopt measures to assure penal sanc-tions for intenitional offenses which are contraryto the provisions of the convention (includingpossession anid purchase). On the other hand, aprominienit newv feature of the convention is arti-cle 38, wlicll provides the following.

Treatnicnt of Druig Addicts

1. The Parties shall give special attention to the pro-visioin of facilities for the medical treatment, care andrehabilitation of drug addicts.

2. If a Party has a serious problem of drug addictionand its economic resources permit, it is desirable thatit establish adequate facilities for the effective treat-inent of drug addicts.

Federal ActionThe Ha.rrison Act of 1914, implementing the

Hague Convention of 1912, was a tax act witha clear regulatory purpose upheld by the Su-preme Court (10). With the help of thephysician-plenipotentiary from the Hague con-ference (11), the authors spelled out require-ments and prohibitions appropriate to limit theimportation, production, sale, and use of opi-ates to medicinal and scientific purposes. Theyexempted from the act's prohibitions, although

Public Health Reports588

not from all requiremenits, the use of narcoticdrugs by a registered l)hysician in the course ofhis professional practice only (2).

Since the Harrison Atct, Congress has broad-ened its concept of the constitutional base forFederal legislation regardinig narcotics well be-yond the taxinlg power. In stating the basis forthe Narcotics Manufacturing AX-ct of 1960, Coni-gress inielude-d the internationial obl igoat ions ofthe United States and the promotion of publichealth, safety, anld welfare, as well as the regula-tioin of interstate anid foreigni commierce (12).Crlimlinial sanictionis have been provided as neces-sairy and proper in the exercise of these powers,but since tlhese sanctionis rest on the same con-stituitional basis as "all laws wlich slhall benecessary anid pi-oper for carryinig inito Execu-tion the foregoinlg Powers," Conlgress has niotbeeni limilited to criminial sanietions.The Public Health Serice program for nar-

cotic ad(lictioin was iniitiated by Puiblic Law672 of the 70tlh Conigress, eniacted Ja-Inuary 19,192)9. Iilnder tlis law, codified in the PuiblicHealtlh Service Akct ini 1944, tlhe program in-cluded fotir balsic elemiienits.

1. Treatmiienit aind relhabilitationi of niarcoticdruig adldicts wlho are convi-icted of Federaloffellses.

2. Prevention of Federal niarcotics offenlses bytreatminent anid rehabilitationi of v-oluntary pa-tielnts, as well aIs those allready convicted of Fed-eral offenises.

3. Encouraging ancld assistinig States and theirconistituieint coinmunlililit ies to provide adequatefacilities and methods for the care of their nar-cotic, addicts w-ith the beniefit of Federal co-operation and experienlce.

4. Resealrchl aincd tralinling in the causes, diag,-nosis, treatnient, control, anid prevention of niar-cotic drug addiction.The Puiblic Hlealth Service hospitals at Lex-

ilngtontll y., opeeled in 1935, and'1at Fort Wortlh,Tex., openied in 1938, lhave provided treatmenta(ld relhabilitationi servNices for prisoniers, pro-bationers, ani(l voluntary p)atients in an inlstitu-tioIn elss prisoni-like in appearance tlhani mostprisons anid miore prison-like than most lhos-pitals' (13). \oluiitary platients, lhowever, couldland (lid leave wlihen they pleased, following aFederal clistrict court decision that statutoryprovisions for their treatmenlt for the time

necessary "to effect a cure" must be initerpreted,in order to avoid constitutional questions, asnot autlhorizing inzvoluntary detention fortreatmient (14).

Research and trainiln-g activities were alsocarried on, anid consultative services wvere pro-vided to State and local agencies to assist tlhemin tlhe prevention and treatment of addiction.There may have been an unintended side effect,establishing a national image of Lexington andFort Worth as the primary pllaces for treatinentof narcotic addicts, dlespite the purpose and pol-icy of encouraging States and comim-iunities todevelop their owv-n programs. B3oth hospitals areniow being Cconvert,ed inito researchl centers by thleNation.al Institute of AMenital Healtlh, and theFederal Bureau of Prisonis, whose medical serv-ices ar-e provided by the Puiblic Hlealtlh Service,is developing a treatment program for its ad-di ct-prisoniers.

Ain Institute onI Newv Developmenlts in theRehabilitation of the Narcotic ANcddict, held atFort Wortli, Tex., Februiary 1966 (15), de-scriibe(d inno-ations in the Federal treatmentprograms p)recedinig the Narcotic Addict Re-habilitation.Atct of 1966.Aside from the Public Healtlh Service pro-

gram, Federal emplhasis in the field of narcoticabuse from 1914 to 1966 was oni rigorous en-forcement of the existing Federal lawvs withincreasing lpenalties ancd less opportunity forprobation or parole, additional legislation totighten controls anid to extend simrwilar conitrolsto syntlhetic narcotics anid miiarijuaina, encourage-ment of State legislation suelh as the UlniformNarcotic Drulg Act, which wvas eniacted byCongress for the District of Columbiat in 1938,anid cooperation with State anid local eniforce-menit agencies (16).

DuIring this period there was extensive liti-gation ancd controversy over the practicaliniterpretation of tlhe Federal laWv's exemptioni ofthe use of niarcotics by a physician "in the courseof hiis profession(al practice onily," eitlher byadministering(- or dispenisiig theii "to a patienit"or by issuill(ng Awritten "prescription." Lergalissuies turinedl on time mean1e1ing Of worcds suclh as

those qutoted; behilid tlhe legal issues were con-flictingr viewvs of tIme legitimiate scope of govern-mental-especially Federal-conitrol of plhysi-ciais' conlduct.

Vol. 83, No. 7, July 1968 589

When a physician sold 4,000 narcotics ordersin 11 months to anyone paying 50 cents each,the U.S. Supreme Court held that "to call suchan order . . . a physician's prescription wouldbe so plain a perversion of meaning that nodiscussion of the subject is required" (17).When another physician was convicted on avery different set of facts, the Supreme Courtsaid, "It [the Harrison Act] says nothing of'addicts' and does not undertake to prescribemethods for their medical treatment. They arediseased and proper subjects for such treatment,and we cannot possibly conclude that a physicianacted improperly or unwisely or for other thanmedical purpose solely because he has dispensedto one of them, in the ordinary course and ingood faith, four small tablets of morphine orcocaine for relief of conditions incident to addic-tion. What constitutes bona fide medical practicemust be determined upon consideration ofevidence and attending circumstances" (18).Between these polar decisions there was

enough area of controversy and uncertainty tolead the President's Advisory Commission onNarcotic and Drug Abuse (the Prettyman Com-mission) in 1963 to recommend "that Federalregulations be amended to reflect the generalprinciple that the definition of legitimatemedical use of narcotic drugs and legitimatemedical treatment of a narcotic addict areprimarily to be determined by the medicalprofession" (19).While retaining the pertinent language of

the Treasury regulations, the Bureau ofNarcotics in March 1966 issued a revised pam-phlet, "Prescribing and Dispensing of NarcoticsUnder the Harrison Narcotic Law" with a"Dear Doctor" statement of its purpose "to gen-erate interest in treating and curing addictionand to make clear that the policy of the U.S.Government does not restrict physicians whodesire to treat narcotic drug addicts in thecourse of ethical practice of medicine" (20).The pamphlet cites court decisions, but is

mainly a compilation of statements from theAmerican Medical Association and the NationalResearch Council. The latest and most extensiveof these is the report of the association's Councilon Mental Health and the National Academy ofSciences-National Research Council's Com-mittee on Drug Addiction and Narcotics, issued

in June 1963. This report reviews currentmedical opinion in recognition of- the fact that"expressions of prevailing medical opinion havea profound impact not only on medical practicebut on regulations, laws, and courts, and thatit is the duty of the medical profession to reviewits expressed opinions regularly in order toassure their current validity." A revision of thereport has since been published in an effort tomaintain a current code of ethical medical prac-tice in respect to narcotics and narcotic addic-tion (21).A major landmark at the Federal level since

1914 is the Narcotic Addict Rehabilitation Actof 1966 (NARA) with its accompanying dec-laration of policy in favor of civil commitmentfor treatment in lieu of prosecution or sentenc-ing for "certain persons charged with or con-victed of violating Federal criminal laws, whoare determined to be addicted to narcotic drugs,and likely to be rehabilitated through treat-ment . . ." (22). Congress further declared itspolicy and provided legal procedures in title IIIof the NARA for what had previously been leftentirely to the States, namely civil commitmentfor treatment of narcotic addicts not chargedwith any criminal offense.Implementation of the NARA is just begin-

ning, but it already illustrates the complex ofinterrelated roles of government and medicineat international, Federal, State, and local levels.The law conforms to the basic pattern of thenew international convention in leaving undi-minished the Federal legal controls on the pro-duction, distribution, and use of narcotics, butgives "special attention" to the "treatment, careand rehabilitation of drug addicts." Unlikearticle 38 of the UN convention the NARAemphasizes treatment programs more than fa-cilities and defines treatment much more inclu-sively than might be understood from the term"medical treatment."While the legislation leading to the NARA

was described by the U.S. Attorney General as"a first step toward disentangling medical andcriminal elements in the knot of problems wecall drug addiction" (23), the coercive role ofgovernment is continued through civil commit-ment of addicts who are either not charged withany crime or are charged but civilly committedin lieu of criminal prosecution; addicts con-

Public Health Reports590

victed of a Federal crime are sentenced "to com-mitment for treatment."The NARA is a Federal innovation, but the

Federal role is clearly seen as complementary tothat of States and local communities and non-governmental agencies. It provides for "utiliz-ing all available resources of local, public andprivate agencies," and for assisting "States andmunicipalities in developing treatment pro-grams and facilities." It authorizes specialgrants to States, political subdivisions of States,and private organizations and institutions todevelop and evaluate programs, and authorizescooperative arrangements for treatment cen-ters and facilities.An even broader but noncoercive Federal ap-

proach to narcotics abuse is represented in theprograms for community mental health centers(24), for comprehensive health services in"areas having high concentrations of povertyand a marked inadequacy of health services"(25), and for the Federal-State-local "Partner-ship for Health" (26). In all these programsabuse of narcotics is recognized as a specificproblem, but in the first, in the context of com-munity mental health, and in the second andthird, in the context of comprehensive healthservices as part of total community life.Under the Economic Opportunity Amend-

ments of 1966 about $12 million were providedfor community addiction programs as part ofthe comprehensive health services for povertyareas. Also under this act, the legal services pro-gram provides a means of advising addicts andtheir families of available treatment programswhich may be a more hopeful alternative topresent or eventual prosecution for crime (25).

Federal policy as represented by these sev-eral approaches has been described by some asambivalent and by others as balanced in seek-ing the objectives of public safety and a maxi-mum opportunity for addicts to achieve anormal life (15).

State and Local ActionState and local controls against narcotic

abuse may have been chaotic in 1912, but withgrowing Federal influence and the recommen-dations of the Commissioners on UniformState Laws they became largely standardized.Most included prohibitions against any unau-

thorized manufacture, sale (generally includ-ing gifts or other transfers), or possession ofnarcotic drugs (including cannabis or mari-juana by special definition) and with increa.s-ingly severe penalties for violations (16).Treatment of na.rcotic addicts was specifically

authorized by State law at least as early as 1874in Connecticut. In 1909 New York passed a lawfor civil commitment of addicts on their volun-tary application, but failed to provide any fa-cilities for treatment. Addicts, with alcoholics,have been low on the priority list for even suchtreatment as the States provided for mental dis-orders generally. California did authorize aState hospital especially for drug addicts in1927. When a survey was made for the U.S. Sen-ate in 1956, numerous State laws for civil com-mitment and treatment of narcotic addicts hadbeen enacted but few States had facilities to im-plement them and such treatment as there waswas mainly institutional and custodial (27).While published debate over legal restrictions

on what physicians may do with addicts hascentered on the Federal law, similar questionsarise under State laws. State jurisdiction overmedical practice of course differs from Federaljurisdiction, but there is still the underlyingproblem of defining legitimate governmentalcontrol of physicians' conduct. The UniformNarcotic Drug Act is similar to the Federal lawin permitting a physician to prescribe, admin-ister, or dispense narcotics "in good faith andin the course of his professional practice only."California, however, has imposed detailed speci-fications for the treatment of addicts by physi-cians, ranging from the place of treatment tothe dosage of narcotics to reports of progressand treatment (16).

Several States made addiction itself a crime,although it never has been under the Federallaw. This led to a landmark Supreme Court de-cision in 1962, holding it to be unconstitutionalto punish addiction, a disease, as a crime. Butother measures against narcotic abuse were notdirectly affected by the decision, and in factwere encouraged by the Court's discussion ofthe problem. The Court said (28):Such regulation, it can be assumed, could take a

variety of valid forms. A State might impose criminalsanctions, for example, against the unauthorized man-ufacture, prescription, sale, purchase, or poissession of

Vol. 83, No. 7, July 1968 591

narcotics withini its borders. In the interest of diseour-aging the violatioii of such laws, or in the interest ofthe genier.al health or welfare of its illhabitants, a Statemight establish a program of compulsory treatmeint fo,rthosie addicte,d to niarcotics. Such a program of treat-inenit imiight requiire )eriods of involuntary conifineiimeint.And penal sanletions mighlt be impoosed for failure tocolmply with established compulsory trea.6litment pro-cedures. Or a State mlighlt choose to attack the evilsof niarcotics traffic oni broader froints also through1public health e(ducatioin for examiiple, or by efforts toaimieliorate the econoimiic aind social conditionsx uinderwlhich those evils might be thoug,ht to flouirish.

AMajor recent developments in State lawvs inldi-cate an approach similar to that of the SupremneCourt.

1. Commitment for treatment, wvitlh both in-stitutional a1ind communnulaity care, for addictsclha.rged with (a C1rim1ilnal offenise iwho elect treat-ment in lieu of prosecuitioni anid are consideredsuital)le for treatmleint cas in Nelw Yor-k since,1962 anid under title I of the NARA (15., 22).

2. Invi-oluniitary commitmnent for both institu-tionial anid com.munity care of addicts notcharged with any crime-as in New York (29)beginning April 1, 1,967, in C(alifornia, anid in-dei title III of the NARA.

3. Commlllitmenit of selected addicts for treat-ment. (w-ith or without their conisent) after con-victioni of crimie. Tlis is a recenit dev-elopment, inprogra1n ratlher tlhain in principle anid varieswith programi ldev-elopinent. Its major innov-a-tion is the coml)ination of institutional anid comii-mimnity care a-as in Californiia anid millder title IIof thle NARA (15. 2,2.).

Suchl laws, in providing for both hospital anltposthospital care, cause at least a partial shiftof emphasis froin-more or less isolated facilitiesto comm-unmity treatmenet. At least there is a sig-nificanlt clhange fIrolml the situalxtionl described bya New York State, legislati-e comnmlittee as re-cently a.s 1959 wh-len it reported, "N'arcotics ad-diction reprelsenits perhaps the one mnajor menitalhealtlh disease, entity wlichl is n0ow comipletelyigniored by commnunuity imienitaCl he(alth re,sources"(30). Tlhis lol-ve toward comminlllUllitv care is

stimul-ated by the N,ARA,, thle communll1ity nlltalhealth ceniters program, an(l tlhe comlprehelnsivehealth services p)rogram munmder the EconomuwCOpportunity Act. It lh.as also been recomnnendedat the initernational. lev-el by experts of theAVorld Hetalth Organization, although the neewUTN convention is silenit on the subject.

Tlhe distinction between Federal programsand State or local programs for the preventionaniid treatment of narcotic addiction beicomes adistin1ctioni of roles rather than of progranmsas the progranms themselves become joinlt en-terprises of Federal, State, and local agencies,wi'itl botlh governmiental anid nongovernnment alparticipation. The hiistory of this trend remiainsto be miade, as well as to be written. AMany ofthe inno10vatiolns of the last felwv years in separateFederal, State, and local programs and in coim-mnunity programs wvith Federal anld St-ate sup-port are described in the report of the 1966Institute on New- T)evelopments in the Rehabili-tationl of the NarcoticcAddict (15).Beyond the direct operation. of comnmunity

programns by public and private agencies, thereis whliatever stimulative effect such law-s andprogr-ams may have oil the treatment of addictsin the private practice of medicine, Witlh thleencouragement of the Bureau of Narcotics "totreat niarcotic. drug addicts in the course, ofethical practice of nmedicine"' (20). If practicingphysicians are more pluralistic thalni law en-forcemiieinit agencies in their views of what isethictail in tIme treatmneit of addicts, channiiels ofexpr-ession are available to carry oni thle conl-tilUi ng review recommended by the committeesof the Am-iericain Medical Association anid theNationla,l A-ccademny of Sciences-Nation-al Re-sea-rch CoUncil.

Conclusions

The hiistory of niarcotic abiuse, as a, medical-sociial problem in the UInited States slow-s acomplex of legal and medical roles and of policydlevelopiiiment at initernationial, Federal, State,anid local levels. It extteinids fromi-i early State andlocal, pul)lblic aind professionial, efforts to controlnalrcotic (abuse to suclh recent de-velopml1enits asU-nited States accession to the United Nationissill gle convenll-tioll, the Federal Na.rcotic AddictRehabilitation Act of 1966, new State laws anidprograis for treatment as w-ell as legal conitrols,m(uid the -applicationi of broader governmenit ap-pro,ac,les through the commuiunity mental healtlcenters pr'ogramti and the coomprehensive healthservices pr)ogiaii-i for poverty area.s. Related toall suchl developments is the role of mediciiie,1o)th liubllic anid private, in providing profes-sionial services, forining public policy, anid de-

Public Health Reports592

fining the relation between government andmedicine. Public health agencies may occupy astrategic position, at least for communications,in this complex of government and medicine andinterjurisdictional relations.

REFERENCES

(1) Treaties and Other International Acts Series, No.6298. U.S. Government Printing Office, Wash-ington, D.C., 1967.

(2) Public Law 233, 63d Cong., 3d sess., Dec. 17, 1914.(3) Terry, C. E., and Pellens, M.: The opium problem.

Haddon C'raftsmen, Camden, N.H., 1928.(4) Wilbert, M. I., and Motter, M.: Digest of laws

and regulations in force in the U.S. relating tothe possession, use, sale, and manufacture ofpoisons and habit-forming drugs. Public HealthBull 56: 14-15, November 1912.

(5) U.S. Senate: Document No. 736. 61st Cong., 3dsess.. U.S. Government Printing Office, Wash-ington, D.C., 1911.

(6) Public Law 221, 60th Cong., 1st sess., Feb. 9,1909.

(7) 38 Stat. 1912, Treaty Series No. 612. U.S. Govern-ment Printing Office, Washington, D.C.

(8) President's message, convention on narcoticdrugs: Senate Doc. Executive G, Annex A. 90thCong., U.S. Government Printing Office, Wash-ington, D.C., Mar. 8, 1967.

(9) U.S. Senate: Executive report 11. 90th Cong., 1stsess., U.S. Government Printing Office, Wash-ington, D.C., May 8, 1907.

(10) U.S. v. Doremus, 249 U.S. 86 (1919).(11) Hamilton Wright, M.D.: Dictionary of American

Biography. Charles Scribner's Sons, New York,1936, vol. 20, p. 552.

(12) Public Lawv 429, 86th Cong., 2d sess., Apr. 22,1960.

(13) Lowry, J. V.: Hospital treatment of the narcoticaddict. Federal Probation 20: 42, December1956.

(14) Re Lloyd 13 Fed. Supp. 1005 (Eastern Dist., Ky.,1936).

(15) Rehabilitating the narcotic addict. U.S. Govern-ment Printing Office, Washington, D.C., 1967.

(16) Eldridge, W. B.: Narcotics and the law, AmericanBar Foundation. New York University Press,New York, 1962.

(17) WVebb v. U.S., 249 U.S. 96 (1919).(18) Linder v. U.S., 268 U.S. 5 (1925).(19) President's Advisory Commission on Narcotic

and Drug Abuse: Final report. U.S. Govern-ment Printing Office, Washington, D.C., No-vember 1963, pp. 8, 57-60.

(20) U.S. Bureau of Narcotics: Prescribing and dis-pensing of narcotics under the Harrison Nar-cotic Law. Treasury Pamphlet No. 56. U.S.Government Printing Office, Washington, D.C.,March 1966.

(21) Narcotics and Medical Practice. JAMA 202: 209-212, Oct. 16, 1967.

(22) Public Law 89-793, Nov. 8, 1966, 80 Stat. 1438.(23) U.S. Senate Judiciary Committee: Hearings be-

fore Special Subcommittee of Senate JudiciaryCommittee on S. 2113, 2114, and 2152. U.S. Gov-ernment Printing Offlce, Washington, D.C., Jan.25, 1966, p. 14.

(24) P.L. 88-164 (1963), P.L. 89-105 (1965), P.L. 90-31(1967).

(25) P.L. 89-794 (1966), sec. 216.(26) P.L. 89-749 (196).(27) U.S. Senate Judiciary Committee: Summary of

State and D.C. legislation relating to treat-ment of drug addiction. Doc. No. 120. 84th Cong.,2d sess., U.S. Government Printing Office, Wash-ington, D.C., 1956.

(28) Robinson v. California, 370 IU.S. 660 (1962).(29) N.Y. Laws 1966, ch. 192.(30) Report of the State of New York Joint Legisla-

tive Committee on Narcotic Study, Albany,1959, p. 60.

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