Solem v. Helm

Controversy still surrounds repeat offender laws as more states adopt these policies. With two separate decisions in two similar cases: Rummel v. Estelle and Solem v. Helm, states continue to grapple with the problem of what to do with habitual felons. In California, for example, the "three strikes" law sent a man to prison for life for stealing two packs of cigarettes as well as a man who stole a slice of pizza, because they were previously convicted of multiple felonies. Solem v. Helm remains the case cited to reduce these kinds of sentences, while Rummel v. Estelle remains the case cited to issue such sentences.>Controversy still surrounds repeat offender laws as more states adopt these policies. With two separate decisions in two similar cases: Rummel v. Estelle and Solem v. Helm, states continue to grapple with the problem of what to do with habitual felons. In California, for example, the "three strikes" law sent a man to prison for life for stealing two packs of cigarettes as well as a man who stole a slice of pizza, because they were previously convicted of multiple felonies. Solem v. Helm remains the case cited to reduce these kinds of sentences, while Rummel v. Estelle remains the case cited to issue such sentences.

The court of appeals noted that Rummel v. Estelle was distinguishable. Helm's sentence without parole was qualitatively different from Rummel's life sentence with the prospect of parole because South Dakota has rejected rehabilitation as a goal of the criminal justice system.