Harmelin v. Michigan

Supreme Court of the United States · 1991 · Criminal Law

501 U.S. 957 (1991)

Updated August 1, 2026

Criminal LawproportionalityEighth Amendmentsentencingcruel and unusual punishmentsmandatory life without parolenoncapital sentencingindividualized sentencing

Facts

Petitioner was convicted of possessing 672 grams of cocaine. Michigan law required a mandatory sentence of life imprisonment without possibility of parole for possession of 650 grams or more of a mixture containing cocaine. Petitioner argued that the sentence was cruel and unusual because it was significantly disproportionate to his crime and because the sentencing judge was required to impose it without considering the particular circumstances of the offense or the offender. The case concerned only the constitutionality of the sentence, not the validity of the conviction.

Issue

Does the Eighth Amendment prohibit a mandatory sentence of life imprisonment without possibility of parole for possession of 672 grams of cocaine, either because the sentence is disproportionate to the offense or because the sentencer could not consider mitigating circumstances in a noncapital case?

Rule

Under Justice Scalia's opinion, the Eighth Amendment does not contain a proportionality guarantee for sentences of imprisonment in noncapital cases. It also does not require individualized sentencing or consideration of mitigating factors before imposing a mandatory sentence of life without parole outside the capital context.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Devin Morales is convicted of a noncapital felony after police find a large cache of contraband in his warehouse. A state statute requires a 45-year prison term, and Devin argues the sentence is unconstitutional solely because it is far too severe for the offense.

Under the governing Eighth Amendment rule from the lead opinion, how should a court rule on Devin's claim?

Explanation. The lead opinion concluded that the Eighth Amendment contains no proportionality guarantee for noncapital terms of imprisonment. The Clause is directed at cruel and unusual punishments as modes or methods, not at judicial review of the length of prison terms for felonies. Because Devin challenges only the severity of a noncapital prison term, his Eighth Amendment claim fails under that reasoning.