Solem v. Helm Case Brief Summary | Law Case Explained
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Solem v. Helm | 463 U.S. 277 (1983)
The Eighth Amendment protects against the imposition of cruel and unusual punishment. The Supreme Court has recognized that methods of punishment that are disproportionately severe in comparison to a defendant’s crime may constitute cruel and unusual punishment. But in Solem versus Helm, the Court considered whether the length of a prison sentence may be disproportionately severe under the Eighth Amendment.
In nineteen seventy-nine, Jerry Helm wrote a check for one hundred dollars from a nonexistent bank account and was convicted for the crime of uttering a no-account check. The maximum sentence for Helm’s crime was five years’ imprisonment and a five-thousand-dollar fine. However, because this was Helm’s seventh felony conviction in South Dakota, he was sentenced to life imprisonment without possibility of parole under South Dakota’s recidivist statute.
Helm appealed, arguing that because all of his convictions were for nonviolent offenses, his sentence violated the Eighth Amendment. After the state supreme court affirmed the sentence, Helm filed a habeas corpus petition against Herman Solem, the state penitentiary’s warden. The district court denied Helm’s petition, but the Eighth Circuit reversed, ruling that Helm’s sentence was grossly disproportionate to the nature of his crime. The United States Supreme Court granted cert.
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