Rummel v. Estelle, Corrections Director

Between 1964 and 1973, William James Rummel (defendant) was convicted three times for nonviolent property felonies totaling about $230 in value. Under Texas's especially harsh recidivism statute, his third conviction triggered a mandatory life sentence. Rummel didn't dispute that Texas could treat his crimes as felonies, but argued in a habeas corpus action against Estelle, the state's corrections director, that a life sentence for such minor nonviolent crimes was so disproportionate that it violated the Eighth Amendment. The district court denied relief, a circuit panel reversed, but the full circuit court sitting en banc reinstated the district court's judgment, emphasizing Rummel's eligibility for parole after 12 years.