Solem v. Helm

Helm (defendant), with six prior nonviolent felony convictions, pleaded guilty to passing a $100 no-account check, an offense ordinarily carrying up to five years and a $5,000 fine, but South Dakota's recidivist statute allowed a life sentence for offenders with at least three prior felonies, and the trial court imposed life without parole -- the most severe sentence available under state law -- which the court of appeals found grossly disproportionate.