Ewing v. California

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Following is the case brief for Ewing v. California, Supreme Court of the United States, (2003)

Case summary for Ewing v. California:

  • Ewing was charged and convicted for stealing three golf clubs.
  • Ewing previously committed two offenses, ripe under the states “three strikes” law.
  • After receiving a sentence of 25 years imprisonment, Ewing challenged the law’s constitutionality under the Eight Amendment’s ban on cruel and unusual punishment.
  • The Court held that after considering Ewing’s conviction for stealing golf clubs worth $1,200 subsequent to committing four serious or violent felonies, the sentence was appropriate by California’s interest in public safety from repeat offenders.

 Ewing v. California Case Brief

Statement of the facts:

Ewing, who had prior convictions including three burglaries and a robbery, was arrested for stealing three golf clubs. The state of California had a three strikes law which sentenced defendants who had previously been convicted of two violent or serious felonies to undetermined life imprisonment terms. Under this law, the courts possess the discretion to avoid the three strikes rule by vacating allegations of prior violent or serious felonies. Once charged with grand theft, the state decided to invoke the three strikes rule. At trial, Ewing was found guilty and sentences to 25 years imprisonment.

Procedural History:

Ewing appealed and the Supreme Court of the United States granted certiorari.

Rule of Law or Legal Principle Applied:                         

The prohibition against cruel and unusual punishment under the Eighth Amendment is not violated when a repeat felon is sentenced to a prison term of 25 years according to a state’s three strikes law.

Issue and Holding:

Whether a 25 years prison sentence under california’s three strikes law violates the Eighth Amendment’s prohibition on cruel and unusual punishment. No.

Judgment:

The Court affirmed the lower court’s convictions.

Reasoning:

The Eighth Amendment of the Constitution does not prohibit a 25 year sentence for serious habitual offenders. The Court referred to

Harmelin v. Michigan, 501 U.S. 957 (1991), which limited the proportion of punishment in regarads to what is cruel and unusual for cases that did not involve the death penalty.

Here, California’s interest in protecting their public’s safety from habitual offenders resulted in the three strikes laws. The intent of the state legislature was to remove repeat serious or violent offenders from the public. Statistics support that more than 60 percent of those released from prison commit another serious crime within three years of their release.

The Court held that these recidivism laws further the goals of both incapacitation and deterrence, as the state noted a 25 percent drop in its recidivism rate subsequent to passing the law. There exists no great disparity or disproportion between the seriousness of the sentence and the committed offense.

Concurring or Dissenting opinion:

Concurring (Scalia):

The Eighth Amendment’s bar on cruel and unusual punishment was not meant to prevent disproportionate sanctions, but certain modes of criminal punishment. In addition the consideration of the proportionality principle should only be implemented where the overall goal of punishment is retribution. Proportionality by itself cannot justify Ewing’s sentence of 25 years to life for shoplifting golf clubs. Policy regarding the public’s safety should be considered and is a better justification.

Concurring (Thomas):

The prohibition of cruel and unusual punishment under the Eighth Amendment does not require the consideration of proportionality.

Dissenting (Breyer):

Whether or not Ewing’s sentence was proportionate to the crime he committed is the issue to be determined by the Court. The crime of shoplifting, though a serious problem, is not proportionate to 25 years of imprisonment.

Dissenting (Stevens):

The Eighth Amendment to the U.S. Constitution bars excessive punishment. Judges possess the authority to determine which forms of punishment are allowed pursuant to the amendment.

Significance:

This case set out the importance of public policy, specifically public safety, of the “rational legislative judgment” behind convictions.

Student Resources:

https://supreme.justia.com/cases/federal/us/538/11/
https://www.law.cornell.edu/supct/html/01-6978.ZS.html