Solem v. Helm
Solem v. Helm is a significant U.S. Supreme Court case that addressed the constitutionality of harsh sentencing under habitual offender laws. The case involved Jerry Helm, who was sentenced to life imprisonment without the possibility of parole for writing a bad check, marking his seventh felony conviction. While Helm's crimes were nonviolent and relatively minor, South Dakota's habitual offender statute allowed for severe penalties after multiple felony convictions. The Supreme Court, in a closely contested 5-4 decision, ultimately overturned Helm's sentence, highlighting issues of proportionality in punishment.
Justice Lewis F. Powell, Jr., writing for the majority, argued that the Eighth Amendment's prohibition against "cruel and unusual punishment" encompasses more than just barbaric practices; it also demands that sentences be proportionate to the crimes committed. The ruling emphasized that a life sentence for several minor offenses was disproportionate, especially in comparison to punishments for more serious crimes like murder and rape. This decision has had a lasting impact on discussions surrounding sentencing laws and the principles of justice in the United States.
Solem v. Helm
Date: June 28, 1983
Citation: 463 U.S. 277
Issue: Cruel and unusual punishment
Significance: The Supreme Court held that the Eighth Amendment’s proscription of cruel and unusual punishment prohibited disproportionately severe penalties in noncapital cases.
When Jerry Helm was convicted of writing a bad check, it was his seventh felony conviction in South Dakota. All the offenses had been relatively minor, nonviolent crimes against property. Under the state’s habitual offender statute, however, a person convicted of four felonies could be given the maximum penalty for a class-one felony. Helm was sentenced to life imprisonment without possibility of parole. In Rummel v. Estelle (1980), the Supreme Court had voted five to four to allow Texas to impose a penalty of life imprisonment, with the opportunity for parole, for a man who had been convicted of three separate theft offenses that totaled $289. Justice Lewis F. Powell, Jr., dissented in that case.
By a 5-4 vote, the Court overturned Helm’s sentence. Powell, in the majority opinion, argued that the term “cruel and unusual” referred to more than barbaric practices, and he insisted that the principle of proportionality applied to felony prison sentences. Spending one’s life in prison was out of proportion to the commission of several relatively minor crimes, and it was also disproportionate in the sense that it was harsher than punishments often given to people for more serious crimes, such as rape and murder. In Harmelin v. Michigan (1991), nevertheless, the Court voted five to four to uphold a life sentence, without possibility of parole, imposed on an individual for possessing 772 grams of cocaine.