Rummel v. Estelle

Following his conviction and sentencing, Rummel attempted to appeal his case to the Texas Court of Appeals. The court rejected his appeal, however, and Rummel subsequently filed a petition for a writ of habeas corpus to the U.S. District Court for the Western District of Texas. Rummel claimed in his petition that a life sentence was so out of proportion to the damage done by his crimes, which were nonviolent and involved a total property value of $229.01, that it violated Eighth and Fourteenth Amendment prohibitions against cruel and unusual punishment of criminals. The district court rejected Rummel's constitutional claims, pointing out that he would be eligible for parole in approximately 12 years, regardless of the initial length of his sentence. Rummel then brought his case before a panel of the U.S. Court of Appeals for the Fourth Circuit. The circuit court overruled the district court, ruling that Rummel's punishment was "grossly disproportionate" to his crimes. Following this ruling, the court of appeals reheard the case, vacating the opinion of the circuit court panel's decision and reaffirming their earlier decision and agreeing with a dissenting circuit court panel judge that "no neutral principle of adjudication permits a federal court to hold that in a given situation individual crimes are too trivial in relation to the punishment imposed." The court of appeals also affirmed the district court's denial of Rummel's petition for a writ of habeas corpus. In reaching its conclusions, the court of appeals relied heavily on the probability that Rummel's sentence would actually turn out to be considerably less than life, due to the probability of his parole after an approximately 12-year period. Significantly, six members of the court of appeals dissented in the final decision, noting that Rummel had no guarantee of parole and therefore the constitutionality of his sentence should be determined on its face, and not on the basis of perceived probabilities. With such deep disagreement within the court of appeals, the case was sent to the U.S. Supreme Court, which heard arguments on 7 January 1980.