Solem v. Helm case brief

Solem v. Helm case brief summary
463 U.S. 277 (1983)

CASE SYNOPSIS

Respondent warden appealed the decision of United States Court of Appeals for the Eighth Circuit, which reversed the decision of a trial court and granted petitioner inmate's request for habeas corpus relief. The inmate had been sentenced to life imprisonment without parole for a seventh felony. The appellate court found that the sentence violated the Eighth Amendment because it was grossly disproportionate.


CASE FACTS
The inmate was convicted of uttering a "no account" check. The inmate's six previous felonies were all for nonviolent, minor crimes. Pursuant to S.D. Codified Laws § 22-7-8 (1979), the inmate was sentenced as a recidivist.

HOLDING
On appeal, the United States Supreme Court agreed that habeas corpus relief was proper.

DISCUSSION

• A sentence had to be proportionate. 
• A proportionality analysis could apply to felon prison sentences. 
• The court looked to three factors in determining proportionality. 
• The first was the gravity of defendant's offense, which was minor, and there was no evidence that defendant was a career criminal. 
• Second, viewing other sentences in the same jurisdiction, the inmate could have received the same sentence for murder or other heinous crimes. 
• Third, the court viewed sentences for the same crime in other jurisdictions. 
• Only one other state allowed for so severe a punishment. 
• The fact that the inmate's sentence could have been commuted was not a factor. 
• Commutation was different from parole, and commutation was much harder to obtain. 
• Even if the sentence were commuted, the inmate would only have been eligible for parole, and there was little proof he would have received it.

CONCLUSION
The appellate court's decision reversing the denial of habeas corpus relief was affirmed. The inmate's sentence violated the Eighth Amendment because it was cruel and unusual and disproportionate to the crime committed. The fact that the sentence could have been commuted did not detract from its disproportionality.



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