Coercive treatment approaches for drug addiction have been utilized consistently throughout the twentieth century, beginning with the morphine maintenance clinics of the 1920s. Federal narcotics treatment facilities were established in Fort Worth, Texas and Lexington, Kentucky in the 1930s. In 1962, the U.S. Supreme Court held, in Robinson v. California (370 U.S. 660), that a state could establish a program of compulsory treatment for narcotic addiction and that such treatment could involve periods of involuntary confinement, with penal sanctions for failure to comply with compulsory treatment procedures. In 1966, Congress passed the Narcotic Addict Rehabilitation Act (28 U.S.C. sections 2901-2903) that permitted federal judges and prison officials to refer narcotic-addicted probationers and inmates to the Lexington and Fort Worth facilities as an alternative to traditional incarceration. This Act established statutory authority for involuntary inpatient and outpatient treatment and treatment in lieu of prosecution...