The Court overturned a life sentence without parole imposed under a recidivist statute (mandating more severe sentences for repeat offenders) on a defendant convicted of seven relatively minor felonies. Three years before, however, in Rummell v. Estelle, the Court declined to hold that a life sentence with parole was a disproportionate sentence for three minor felonies. The Court distinguished these findings on the basis that Helm had no possibility of parole, so his release depended on commutation rather than on parole. The Court suggested that the possibility of receiving parole is much greater than the possibility of commutation, which, according to the Court, is granted 'without reference to any standards.' Although the Court has recently emphasized the difference between parole and commutation, it has also held that, in the absence of a statutorily granted expectation, there is no constitutionally protected right to parole (Greenholtz v. Inmates); moreover, the Court has not always characterized clemency as standardless. It is more likely that the difference between the 'Helm' and 'Rummel' decisions is that the 'Helm' sentence was given in a judge's discretion, and the 'Rummel' sentence was mandated by legislation. The Court is apparently more willing to overturn discretionary sentences than mandated sentences. Also, the proportionality test used in 'Helm' was different from that test applied in death penalty cases such as Coker v. Georgia and Edmund v. Florida. In 'Helm,' the Court emphasized that all the factors for determining proportionality were objective and that no one factor was determinative; in 'Coker' and 'Edmund,' the Court stated that its subjective determination of the severity of the offense and the harshness of the punishment was decisive. Implications are drawn for Supreme Court decisions in future proportionality cases. A total of 114 footnotes are provided.