## Facts

- William James Rummel was convicted in Texas of three nonviolent felonies involving small monetary amounts.
- In 1964, he fraudulently used a credit card to obtain about $80 and received a three-year sentence.
- In 1969, he passed a forged check for $28.36 and received a four-year sentence.
- In 1973, he obtained $120.75 by false pretenses by taking payment for repairs he did not perform.
- Texas applied its recidivist statute based on two prior felony convictions, requiring a mandatory life sentence with the possibility of parole.
- A jury convicted Rummel of the third offense, found the prior convictions true, and the trial court imposed the mandatory life term.

## Issues

1. Whether a mandatory life sentence with the possibility of parole for a third nonviolent property felony, imposed under a recidivist statute, is so grossly disproportionate as to violate the Eighth Amendment as applied to the states through the Fourteenth Amendment.

## Decision

- The Supreme Court affirmed the denial of federal habeas relief in a 5–4 opinion by Justice Rehnquist.
- The Court held that Texas’s mandatory life sentence with the possibility of parole, imposed under its recidivist statute on Rummel’s record, did not constitute cruel and unusual punishment.
- The Court emphasized substantial deference to legislative sentencing choices for noncapital offenses and the state’s interest in punishing repeat offenders more severely.
- The Court treated the availability of parole as relevant to assessing the severity of the punishment and rejected the claim that cross-jurisdictional sentence comparisons were required or dispositive.

## Legal Principles

- Outside the capital context, Eighth Amendment proportionality challenges to prison terms are rarely successful, and courts generally defer to legislative judgments about sentence length for felonies.
- A state may impose enhanced penalties on recidivists based on the judgment that repeated felony conduct justifies harsher punishment than the latest offense viewed in isolation.
- When a sentence includes the possibility of parole, proportionality analysis may account for the realistic effect of parole eligibility rather than treating the term as imprisonment for life in all cases.
- The Eighth Amendment does not require uniform sentencing outcomes among states, and interjurisdictional comparisons are not mandatory or controlling in ordinary noncapital sentencing review.

## Conclusion

The Court held that Texas did not violate the Eighth Amendment by mandating a life sentence with the possibility of parole for a defendant convicted of a third nonviolent property felony under a recidivist statute, reinforcing a high bar for disproportionality claims in noncapital cases.


Rummel v. Estelle, 445 U.S. 263 (1980)