Solem v. Helm

Summary

The Court held that the Eighth Amendment prohibits South Dakota from imposing life imprisonment without parole on Helm for uttering a $100 no-account check after six prior nonviolent felonies. Applying proportionality principles, the Court found the sentence grossly disproportionate because the offense and prior crimes were relatively minor, comparable offenders in South Dakota could receive lesser sentences, and virtually every other State would impose a less severe punishment. The Court distinguished parole from discretionary executive commutation and affirmed the court of appeals' judgment.