The Supreme Court held that the Eighth Amendment’s proscription of cruel and unusual punishment prohibited disproportionately severe penalties in noncapital cases.
When Jerry Helm was convicted of writing a bad check, it was his seventh felony conviction in South Dakota. All the offenses had been relatively minor, nonviolent crimes against property. Under the state’s habitual offender statute, however, a person convicted of four felonies could be given the maximum penalty for a class-one felony. Helm was sentenced to life imprisonment without possibility of parole. In Rummel v. Estelle
In his majority opinion for Solem v. Helm, Justice Lewis F. Powell, Jr., argued that the term "cruel and unusual" referred to more than physically barbaric practices.
By a 5-4 vote, the Court overturned Helm’s sentence. Powell,
Cruel and unusual punishment
Rummel v. Estelle
Weems v. United States