Three-Strikes Law Prosecutions
What is the Three-Strikes Law?
The Three-Strikes Law is a sentencing policy aimed at repeat offenders, primarily serious or violent criminals. Typically, after a person is convicted of three serious crimes (strikes), they receive a mandatory and often life sentence, even if the third offense is relatively minor.
The goal: deter repeat offenders and protect public safety by keeping habitual criminals off the streets.
Key Cases Explaining the Three-Strikes Law in Action
1. Ewing v. California (2003)
Facts:
Gary Ewing was convicted of stealing three golf clubs valued at about $400. This was his third felony strike under California’s Three-Strikes law. He was sentenced to 25 years to life.
Legal Issue:
Does the Eighth Amendment's prohibition of cruel and unusual punishment forbid such a long sentence for a relatively minor theft?
Holding:
The U.S. Supreme Court upheld the sentence, ruling that the sentence was not grossly disproportionate given his criminal history.
Significance:
Established that harsh three-strikes sentences can be constitutional even for relatively minor third offenses.
Emphasized deference to state legislatures in sentencing policy.
Sparked debate on fairness and proportionality in sentencing.
2. Lockyer v. Andrade (2003)
Facts:
Leandro Andrade was sentenced to two consecutive 25-to-life terms under California’s Three-Strikes law for stealing videotapes valued under $100.
Legal Issue:
Did Andrade’s sentence violate the Eighth Amendment's ban on cruel and unusual punishment?
Holding:
The Supreme Court upheld the sentence, finding no violation of the Eighth Amendment.
Significance:
Reinforced the constitutionality of three-strikes sentences for petty crimes.
Highlighted limits of proportionality review.
A key case in validating strict repeat offender laws.
3. Solem v. Helm (1983)
Facts:
Solem was sentenced to life without parole under South Dakota law for his seventh nonviolent felony (writing a bad check).
Legal Issue:
Is a life sentence without parole for a nonviolent, relatively minor felony cruel and unusual punishment?
Holding:
The Court ruled that the sentence was grossly disproportionate and unconstitutional under the Eighth Amendment.
Significance:
Before Three-Strikes laws became widespread.
Set important limits on disproportionate sentences.
Used as a benchmark in later three-strikes challenges.
4. People v. Superior Court (Romero) (1996) (California)
Facts:
Antonio Romero had two prior strikes but committed a minor offense. The prosecutor sought a third-strikes sentence, but the trial court considered dismissing prior strikes.
Legal Issue:
Can a judge dismiss prior strikes to avoid unfair sentencing under California’s Three-Strikes law?
Holding:
California Supreme Court ruled that judges have discretion to dismiss prior strikes in “unusual” cases.
Significance:
Introduced judicial discretion into a rigid sentencing scheme.
Allowed courts to avoid manifestly unjust sentences.
Influenced reform efforts.
5. In re Butler (2009)
Facts:
A California inmate sought resentencing under amended three-strikes provisions, claiming his third strike was nonviolent and should not trigger life sentence.
Legal Issue:
Does retroactive application of modified three-strikes law benefit inmates with nonviolent third strikes?
Holding:
California courts ruled that inmates with nonviolent third strikes can be resentenced under the amended law.
Significance:
Reflected growing legislative and judicial pushback against harsh three-strikes sentencing.
Promoted more proportional sentencing.
6. People v. Williams (1998) (California)
Facts:
Williams was sentenced to 25 years to life for a third felony involving possession of a small amount of drugs.
Legal Issue:
Does possession of drugs as a third strike trigger mandatory life under Three-Strikes?
Holding:
Court affirmed that drug possession can count as a strike but noted the importance of judicial discretion in sentencing.
Significance:
Expanded scope of three-strikes to drug offenses.
Demonstrated controversy over nonviolent offenses triggering harsh sentences.
Summary Table
| Case | Key Issue | Holding Summary | Significance |
|---|---|---|---|
| Ewing v. California (2003) | Cruel & unusual punishment for minor 3rd strike | Upheld 25-to-life sentence | Validated harsh sentencing |
| Lockyer v. Andrade (2003) | Same as Ewing, theft as third strike | Sentence constitutional | Confirmed broad discretion |
| Solem v. Helm (1983) | Disproportionate sentence for minor felony | Sentence unconstitutional | Set limits on proportionality |
| People v. Romero (1996) | Judicial discretion to dismiss strikes | Judges may dismiss prior strikes | Added flexibility to three-strikes |
| In re Butler (2009) | Retroactive resentencing under amended law | Allowed resentencing for nonviolent strikes | Shift toward fairness |
| People v. Williams (1998) | Drug possession as third strike | Drug possession counts as strike | Expanded three-strikes reach |
Overall Takeaway
The Three-Strikes Law aims to keep repeat offenders off the streets but has faced constitutional challenges.
Courts have generally upheld harsh sentences for repeat offenders but allow some judicial discretion.
Recent reforms and cases promote more proportional sentencing, especially for nonviolent offenses.
These cases reveal ongoing tension between public safety and fairness in sentencing.
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