Nature of the Case
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Facts
Helms (P) was a long time criminal. He had prior convictions of third-degree burglary, obtaining money under false pretenses, grand larceny, and driving while intoxicated. All of these crimes were nonviolent. P was under the influence of alcohol for each crime. P was then charged for uttering a 'no account' check for $100, also while under the influence of alcohol. He pled guilty to this crime, which had the maximum sentence of a $5,000 fine and five years in jail. P was subject to South Dakota's recidivist statute. P's sentence was to be enhanced to a Class 1 felony. P’s maximum sentence was life imprisonment and a $25,000 fine. He received the maximum punishment of life imprisonment. The South Dakota Supreme Court, in a 3-2 decision, affirmed the sentence despite Helm's argument that it violated the Eighth Amendment. Under South Dakota law, prisoners who receive life imprisonment are not eligible for parole but may be eligible for a pardon from the governor. After serving two years, P asked the governor to reduce his sentence to a term of years, so he would be eligible for parole. It was denied. P sought habeas relief. P claimed that his sentence constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments. The United States Court of Appeals for the Eighth Circuit reversed. P's sentence was 'grossly disproportionate to the nature of the offense.' The Supreme Court granted certiorari to consider the Eighth Amendment question presented by this case.
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