Defendant A was convicted twice previously of felonies and sentenced to prison for fraudulent use of a credit card ($80.00) and for passing a forged check ($28.36). Upon his third felony conviction for obtaining money by false pretenses ($120.75), he received a mandatory life sentence under a state recidivist statute.
Thomas E. Baker and Fletcher N. Baldwin Jr,
Eighth Amendment Challenges to the Length of a Criminal Sentence: Following the Supreme Court “From Precedent to Precedent”
, 27 Ariz. L. Rev 25
Available at: http://ecollections.law.fiu.edu/faculty_publications/197