The following excerpt is from Cocio v. Bramlett, 872 F.2d 889 (9th Cir. 1989):
We recently addressed the constitutionality of a life sentence under the Eighth Amendment in Alford v. Rolfs, 867 F.2d 1216 (9th Cir.1989). In Alford we upheld a life sentence with eligibility for parole after
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In Alford we explained that we must follow the proportionality analysis set forth in Solem v. Helm, 463 U.S. 277, 103 S.Ct. 3001, 77 L.Ed.2d 637 (1983), to determine the constitutionality of a prison sentence against an eighth amendment challenge. Alford, at 1221-22.
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