The United States Supreme Court has held that a sentence of life imprisonment without parole imposed in accordance with a state recidivist statute on a defendant after his seventh non-violent felony conviction constitutes cruel and unusual punishment.
Solem v. Helm, 103 S. Ct. 3001 (1983).
Russell K. Broman,
Constitutional Law - Eighth Amendment - Cruel and Unusual Punishment - Criminal Law - Proportionality Review in Non-Capital Sentencing,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol22/iss4/14