In Rummel v. Estelle, the U.S. Supreme Court ruled in 1980 that a life sentence imposed under Texas's recidivist statute did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The petitioner, William James Rummel had been convicted for three nonviolent felonies: fraudulent use of a credit card to obtain $80 worth of goods or services, passing a forged check worth $28.36, and obtaining $120.75 by false pretenses; each conviction was separated from the next by more than four years time period but his third felony triggered an automatic life sentence under Texas law due to his prior convictions. Rummel argued that this was grossly disproportionate given the nature of his crimes and thus violated the Eighth Amendment's prohibition on cruel and unusual punishments. However, Justice Rehnquist delivered an opinion for a divided court (5-4), stating that because states have valid interests in deterring repeat offenders as well as dealing with such individuals who demonstrate criminal propensities despite previous sanctions - it is inappropriate for courts to review length of prison sentences.

In the dissenting opinion for Rummel v. Estelle, Justice Powell argued that William James Rummel's life sentence for a series of minor thefts was grossly disproportionate to his crimes and therefore violated the Eighth Amendment's prohibition on cruel and unusual punishment. He pointed out that in other jurisdictions, such offenses would have resulted in much lighter sentences. Furthermore, he noted that this case raised serious questions about Texas' recidivist statute which mandated life imprisonment after three felony convictions regardless of their severity or nature. Justice Powell believed this law failed to consider individual circumstances adequately and could result in unjust punishments like Rummel's. He also criticized the majority opinion for failing to apply a proportionality principle when evaluating whether a punishment is cruel or unusual under the Eighth Amendment.