Jerry Helm (defendant) had six prior nonviolent felony convictions when he was convicted for passing a “no account” check in the amount of $100. The crime normally carries a sentence of up to five years in prison and a $5,000 fine. Under South Dakota’s recidivist statute, an offender with at least three felony convictions can be sentenced to life imprisonment and a $25,000 fine. Helm pled guilty, and the South Dakota Circuit Court sentenced Helm to life imprisonment without the possibility of parole. The court of appeals reversed on the grounds that the sentence was “grossly disproportionate” to the crime. The United States Supreme Court granted certiorari to consider whether the sentence violated the Eighth Amendment.