The Oyez Project: Criminal Procedure Issues - Cruel and Unusual Punishment, Non-Death Penalty Decisions

Austin v. United States

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Estelle v. Gamble

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Ewing v. California

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Farmer v. Brennan, Warden

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Harmelin v. Michigan

Is a statutorily mandated sentence that does not allow for consideration of mitigating factors a violation of the Eighth Amendment's protection against cruel and unusual punishments?

No. The Court, in a 5-to-4 decision, held that since the Eighth Amendment does not contain a proportionality guarantee, the determination of whether a punishment is "cruel and unusual" is not made with reference to the particular offense. Moreover, the Cruel and Unusual Punishment Clause protects against unusual methods of punishment, not necessarily cruel ones. As such, while Harmelin's life sentence may have been cruel, it was not constitutionally unusual or unprecedented.

Helling v. McKinney

May an inmate sue to prove that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by prison officials who act with "deliberate indifference" to the future health risks associated with second-hand smoke?

Yes. In a 7-to-2 decision, the Supreme Court held that McKinney's suit stated a reasonable claim that, if proven, could be grounds for relief under the Eighth Amendment prohibition of cruel and unusual punishment. Justice Byron White, in the majority opinion, rejected the government's argument that the "deliberate indifference" test established by the Court in Wilson (which held that withholding medical care from prisoners only violated the Eighth Amendment if it was done with "deliberate indifference" to serious health risks) only applied to current medical conditions. If McKinney could prove that the second-hand smoke posed a serious threat to his future health and that the prison officials had deliberately ignored that threat, White wrote, McKinney would be entitled to relief.

Hope v. Pelzer

Does the Court of Appeals holding of qualified immunity where prison guards' conduct violated the Eighth Amendment comport with United States v. Lanier, 520 U.S. 259?

No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the defense of qualified immunity was precluded at the summary judgment phase of Hope's trial. The Court reasoned that, although Hope's allegations if true established an Eighth Amendment violation, prison guards could be shielded from liability for their constitutionally impermissible conduct if their actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. Noting that United States v. Lanier makes clear that officials can be on notice that their conduct violates established law even in novel factual situations, the Court concluded that a reasonable officer would have known that using a hitching post as Hope alleged was unlawful.

Hudson v. McMillian

Must an inmate alleging that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by the excessive use of force demonstrate "significant injury" to prevail on his claim?

No. In a 6-to-3 decision, the Supreme Court held that the degree of injury suffered by an inmate is one of several important factors in an Eighth Amendment claim of cruel and unusual punishment, but that the absence of "significant injury" alone does not mean his rights have not been violated. Instead, the Court should consider whether the punishment inflicted was malicious and sadistic. "When prison officials maliciously and sadistically use force to cause harm, contemporary standards of decency are always violated," Justice Sandra Day O'Connor wrote in the majority opinion. "This is true whether or not significant injury is evident. Otherwise, the Eighth Amendment would permit any physical punishment, no matter how diabolic or inhuman, inflicting less than some arbitrary quantity of injury. Such a result would have been as unacceptable to the drafters of the Eighth Amendment as it is today."

Hutto v. Finney

Did punitive isolation for more than thirty days in the Arkansas prison system constitute cruel and unusual punishment as prohibited by the Eighth and Fourteenth Amendments?

The Court held that punitive isolation for longer than thirty days in Arkansas prisons constituted cruel and unusual punishment and violated the Constitution. Justice Stevens conceded that isolation in and of itself was not necessarily unconstitutional and may in fact serve an important, legitimate interest in administering a prison. However, when taken as a whole, continued Stevens, the conditions in Arkansas's prisons, combined with the severe risks to an inmate's health and safety which accompanied confinement in isolation, did constitute cruel and unusual punishment. "A filthy, overcrowded cell and a diet of 'gruel' might be tolerated for a few days and be intolerably cruel for weeks or months," Stevens concluded.

Ingraham v. Wright

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Powell v. Texas

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Rhodes v. Chapman

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Robinson v. California

Was the California law an infliction of cruel and unusual punishment prohibited by the Eighth Amendment?

In a 6-to-2 decision, the Court held that laws imprisoning persons afflicted with the "illness" of narcotic addiction inflicted cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The Court likened the law to one making it a criminal offense "to be mentally ill, or a leper, or to be afflicted with a venereal disease," and argued that the state could not punish persons merely because of their "status" of addiction. The Court noted that the law was not aimed at the purchase, sale, or possession of illegal drugs.

Rummel v. Estelle

Did Rummel's life sentence under the Texas recidivist law constitute cruel and unusual punishment in violation of the Eighth Amendment?

In a 5-to-4 decision, the Court held that the life sentence imposed by Texas law did not constitute cruel and unusual punishment under the Eighth and Fourteenth Amendments. The Court held that Texas had a significant interest in dealing "in a harsher manner with those who by repeated criminal acts have shown that they are simply incapable of conforming to the norms of society." The Court also noted that Texas had "a relatively liberal policy of granting 'good time' credits to its prisoners," indicating that there was a possibility that Rummel would not be imprisoned for the rest of his life.

Solem v. Helm

Did the sentence violate the Eighth and Fourteenth Amendments?

Yes. Since all of Helm's prior offenses, including his current check-writing conviction, had been "relatively minor" and were not crimes against people, Justice Powell held that Helm had "received the penultimate sentence (South Dakota did not have the death penalty) for relatively minor criminal conduct." Powell concluded that Helm was treated more harshly than the state's most violent criminals.

United States v. Bajakajian

Is the forfeiture of $357,144 cash, a sum involved in the offense of failure to report property in excess of $10,000 while attempting to leave the country, a violation of the Eighth Amendment's Excessive Fines Clause?

Yes. In a 5-to-4 opinion, the Court held that the government's ability to extract fines is limited by the Excessive Fines Clause. The forfeiture of currency, when ordered for a violation of a reporting statute, is a punitive measure which constitutes a "fine" under the Eighth Amendment. Noting the importance of making punishments proportional to their crimes, the Court reminded that currency transportation is generally permissible. Bajakajian's failure to do so within statutory reporting guidelines was neither related to other illegal activity nor did it result in loss to the government. Therefore, forfeiture of the entire sum would be grossly disproportional to the gravity of his offense.

Whitley v. Albers

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Wilson v. Seiter

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