Harmelin v. Michigan
Case Date: 11/04/1991
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Harmelin v. Michigan, 501 U.S. 957 (1991), was a case decided by the Supreme Court of the United States under the Eighth Amendment to the United States Constitution. The Court ruled that the Eighth Amendment's Cruel and Unusual Punishment Clause allowed a state to impose a life sentence without the possibility of parole for the possession of 672 grams of cocaine.
The Court's narrow ruling left a major question of Eighth Amendment law unresolved. Since the Court's decision in Gregg v. Georgia, 428 U.S. 153 (1976), the Court had incorporated a detailed proportionality analysis into the cruel and unusual punishment analysis required in capital cases. The defendant in Harmelin directly asked the Court to extend the reach of that analysis to noncapital cases such as his. Although five Justices agreed that Harmelin's sentence was not unconstitutionally cruel and unusual, six Justices agreed that the Cruel and Unusual Punishment Clause bore some kind of proportionality analysis. Yet among those six, three supported a proportionality principle that is highly deferential to legislative judgments, while three others supported a more searching proportionality analysis that would have struck down Michigan's mandatory life-without-parole sentence for possessing more than 650 grams of cocaine.
The State of Michigan was represented by Richard Thompson and Michael Modelski. Modelski's other credits include serving as a prosecutor of Dr. Jack Kevorkian. As commonly happens in criminal cases before the Supreme Court, various state attorneys general, as well as the United States Solicitor General, filed amicus curiae briefs on behalf of the State of Michigan. The Court appointed counsel for Harmelin, and the ACLU and a group of criminal defense attorneys filed briefs in support of the defendant's position.
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