Rummel v. Estelle

The ruling made it exceedingly difficult to argue the proportionality of sentencing in noncapital cases. The Court subsequently showed flexibility on this issue, however, ruling in Solem v. Helm, (1983) that a recidivist statute in South Dakota which called for mandatory life sentencing without possibility of parole for repeat felons was unconstitutional. The Court has since further complicated its position regarding mandatory felony sentencing, ruling in Harmelin v. Michigan, (1991) that the state of Michigan's statute mandating life sentencing without possibility of parole for first-time felony drug offenders was constitutional.