Rummel v. Estelle - 445 U.S. 263, 100 S. Ct. 1133 (1980)

Rule:

For crimes concededly classified and classifiable as felonies, that is, as punishable by significant terms of imprisonment in a state penitentiary, the length of the sentence actually imposed is purely a matter of legislative prerogative. That, Eighth Amendment judgments should not be, or appear to be, merely the subjective views of individual Justices; judgment should be informed by objective factors to the maximum possible extent.

Facts:

Defendant Rummel committed crimes of credit card fraud in 1964, forgery in 1969, and theft in 1973. Each offense involved small sums but were felonies under Texas law. Defendant was sentenced after the third conviction under a Texas recidivist statute, formerly Texas Penal Code Ann. art. 63, to life sentence. The Texas appellate courts rejected defendant’s direct appeal as well as his subsequent collateral attacks on his imprisonment. Defendant then filed a petition for a writ of habeas corpus. He claimed that his life sentence was so disproportionate to the crimes he had committed as to constitute cruel and unusual punishment. That the ban on cruel and unusual punishments of U.S. Const. amend. VIII and XIV was violated. The district court rejected this claim, noting that this Court had already rejected a constitutional attack upon Art. 63, and then crediting an argument by respondent that defendant’s sentence could not be viewed as life imprisonment because he would be eligible for parole in approximately 12 years. A divided panel of the Court of Appeals reversed. The majority relied upon this Court's decision and a decision of the United States Court of Appeals for the Fourth Circuit in holding that defendant’s life sentence was so grossly disproportionate to his offenses as to constitute cruel and unusual punishment. Defendant’s case was reheard by the court of appeals sitting en banc. That court vacated the panel opinion and affirmed the district court's denial of habeas corpus relief on defendant’s Eighth Amendment claim. Defendant challenged the decision. 

Issue:

Was the denial of defendant’s writ of habeas corpus proper?

Answer:

Yes.

Conclusion:

The Court affirmed the lower courts' denial of defendant's writ of habeas corpus following a life sentence imposed pursuant to a Texas recidivist statute. The court held that sentencing policies were legislative, not judicial, functions. The court explained that eligibility for parole meant that defendant would not actually be imprisoned for the rest of his life. Further, the comparison of recidivist statutes in other states was unavailing because some states would always treat particular offenders more severely than any others. Thus, having twice imprisoned him for felonies, Texas was entitled to place upon defendant the onus of one who was unable to bring his conduct within the social norms prescribed by the state's criminal law. The court then clarified that the mandatory life sentence did not constitute cruel and unusual punishment.