An historical review of Supreme Court cases dealing with the eighth amendment supports the applicability of the proportionality doctrine to all sentences. In Rummel, however, the Court eliminated the use of the doctrine in most eighth amendment challenges to prison sentences and vaguely defined factors that permit other sanctions to be subject to the proportionality analysis. Rummel's appeal to the Supreme Court focused on Texas' authority to impose life imprisonment for the defendant's third nonviolent felony conviction. The Court rejected the appeal, deferring to the State legislature's authority to determine if a punishment is excessive. In Solem v. Helm, the Court was faced with whether the eighth amendment proscribes a life sentence without the possibility of parole for a seventh nonviolent felony conviction. In Solem, the Court observed that the Rummel Court did not expressly reject the application of the proportionality doctrine to punishments of imprisonment. It held that the doctrine was applicable, and an objective analysis of the case was conducted using factors from prior cases. The majority found that Helm's sentence was significantly disproportionate to his crime and therefore unconstitutional. The paper explores reasons why the Court sidestepped its earlier decision and problems future courts will have with the Solem analysis. It includes 160 footnotes.