Summary
The Supreme Court considered whether the Eighth Amendment prohibits a sentence of life imprisonment without the possibility of parole for a seventh nonviolent felony committed by a habitual offender. The Court held that criminal sentences must be proportionate to the offense and identified three objective factors for proportionality review: the gravity of the offense and harshness of the penalty, sentences imposed for other offenses in the same jurisdiction, and sentences imposed for the same offense in other jurisdictions. Applying those factors, the Court concluded that Helm's sentence was grossly disproportionate and affirmed the judgment of the Eighth Circuit.
Topics
Practice areas
Questions Presented
- Whether the Eighth Amendment prohibits a life sentence without possibility of parole for a seventh nonviolent felony.
- Whether the possibility of executive commutation prevents a life-without-parole sentence from being constitutionally disproportionate.
- What objective factors govern proportionality review of noncapital prison sentences under the Eighth Amendment.
Holdings
- The Eighth Amendment prohibits not only barbaric punishments but also criminal sentences that are grossly disproportionate to the offense, including noncapital prison sentences.
- Proportionality analysis should be guided by three objective factors: the gravity of the offense and harshness of the penalty; sentences imposed on other criminals in the same jurisdiction; and sentences imposed for the same crime in other jurisdictions.
- A life sentence without possibility of parole for Helm's seventh nonviolent felony was significantly and grossly disproportionate to his crime and violated the Eighth Amendment.
- The possibility of executive commutation does not make an otherwise unconstitutional life-without-parole sentence proportionate.
Key quotations
“In sum, we hold as a matter of principle that a criminal sentence must be proportionate to the crime for which the defendant has been convicted.” (463 U.S. at 290)
“In sum, a court's proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions.” (463 U.S. at 292)
“The possibility of commutation is nothing more than a hope for "an ad hoc exercise of clemency."” (463 U.S. at 303)
Factual background
Helm had six prior South Dakota felony convictions, all nonviolent and none involving a crime against a person. His seventh felony was uttering a $100 no-account check while intoxicated. South Dakota's recidivist statute authorized a Class 1 felony sentence, and the resulting life sentence carried no possibility of parole; executive commutation was the only potential relief. The sentence was the maximum punishment authorized by South Dakota law for any offense other than capital punishment.
Procedural history
Helm pleaded guilty in South Dakota state court to uttering a $100 no-account check and was sentenced to life imprisonment without possibility of parole under the state's habitual-offender statute. The South Dakota Supreme Court affirmed. The federal district court denied habeas relief, but the Eighth Circuit reversed and directed issuance of the writ unless South Dakota resentenced Helm. The Supreme Court granted certiorari and affirmed the Eighth Circuit.