What is the current state of the law in this case?

Soliz argues his punishment is excessive as a matter of law, particularly in comparison to section 190.2, subdivision (a), which enumerates 22 special circumstances as aggravation factors for the heinous offense of murder. (Solem v. Helm (1983) 463 U.S. 277, 291-292 ["If more serious crimes are subject to the same penalty . . . that is some indication that the punishment at issue may be excessive."].) However, he does not provide other information on comparative sentences for similar crimes in this or any other jurisdictions. Alternatively, he contends that the sentence runs afoul of the federal constitutional guarantee of due process, because in a murder case, the trial court would have had to meet the extensive procedural and substantive requirements of section 190.2. (See Whitley v. Albers (1986) 475 U.S. 312, 327.)