Facts of the Case

Helm was convicted of writing a check from a fictitious account, a crime carrying with it a five-year jail sentence. However, since this was his seventh felony conviction in South Dakota since 1964, he was sentenced to life imprisonment without parole under a state recidivist statute.

Question

Did the sentence violate the Eighth and Fourteenth Amendments?

Conclusion

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.