In Robinson v. California, the Court held that a statute punishing persons for being addicted to the use of narcotics violated the Eighth Amendment. In Powell v. Texas, however, the Justices disagreed over whether the principle underlying Robinson was that crimes must involve an actus reus or that the state may not punish involuntary conduct. Recently, in Jones v. City of Los Angeles, the Ninth Circuit weighed in on the question, holding that the Eighth Amendment forbids punishing involuntary conduct and that Los Angeles therefore could not punish homeless people for sleeping on the streets. ... Writing for the panel, Judge Wardlaw first asserted that the plaintiffs had standing to seek prospective injunctive relief. ... Second, unlike the conception of involuntariness that the Supreme Court adopted in the Fifth Amendment context, it puts no restrictions on what causal factors may be relevant to determining whether a certain outcome was involuntary. ... On this conception of involuntariness, of course, a rule that prohibits punishing involuntary outcomes would undermine criminal law generally. ... The Court's solution was to articulate the narrow rule that a confession is involuntary for the purposes of the Fifth Amendment only if it occurs in the presence of a certain causal factor, specifically, coercive police activity. ... (Copyright 2007 The Harvard Law Review Association)