Eighth Amendment claim (Pennsylvania) · Go Syfert
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Eighth Amendment claim in Pennsylvania

80 Pennsylvania opinions name it 5 courts 1985–2026 29 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (42)

CaseFollowedCited
Tindell v. Department of Correctionsgreen
pacommwct · 2014 · cited in 7 Pennsylvania opinions naming this issue, 2017–2026
2 sentences

2026As to the Eighth Amendment claim, although Petitioner cites to certain impacts on his life caused by the lack of access to the main recreation yard, he has not pled how DOC employees’ “deliberate indifference” to the conditions of his confinement have deprived him of a “single, identifiable human need.” Tindell v. Department of Corrections, 87 A.3d 1029, 1041-42 (Pa. Cmwlth. 2014).

2026As to the Eighth Amendment claim, although Petitioner cites to certain impacts on his life caused by the lack of access to the main recreation yard, he has not pled how DOC employees’ “deliberate indifference” to the conditions of his confinement have deprived him of a “single, identifiable human need.” Tindell v. Department of Corrections, 87 A.3d 1029, 1041-42 (Pa. Cmwlth. 2014).

47
Farmer v. Brennangreen
scotus · 1994 · cited in 7 Pennsylvania opinions naming this issue, 2014–2025
2 sentences

2025In Farmer . . . , the Supreme Court concluded that the inquiry into whether a prison official was deliberately indifferent is a subjective one, requiring the demonstration of a state of mind akin to criminal recklessness, and held that a prisoner must establish that: (i) the prison official knew of and disregarded an excessive risk to inmate health or safety; (ii) the prison official was aware of facts from which an inference could be drawn that a substantial risk of serious harm exists; and (iii) the prison official drew the inference.[] 511 U.S. at 837 , 840 . . . .

2025In Farmer . . . , the Supreme Court concluded that the inquiry into whether a prison official was deliberately indifferent is a subjective one, requiring the demonstration of a state of mind akin to criminal recklessness, and held that a prisoner must establish that: (i) the prison official knew of and disregarded an excessive risk to inmate health or safety; (ii) the prison official was aware of facts from which an inference could be drawn that a substantial risk of serious harm exists; and (iii) the prison official drew the inference.[] 511 U.S. at 837 , 840 . . . .

47
Helling v. McKinneygreen
scotus · 1993 · cited in 4 Pennsylvania opinions naming this issue, 2008–2024
2 sentences

2024See, e.g., Helling v. McKinney, 509 U.S. 25, 35 (1993) (Eighth Amendment claim could be premised upon future harm to health from exposure to environmental tobacco smoke).

2016See, e.g., Helling v. McKinney, 509 U.S. 25, 35 [] (1993) (Eighth Amendment claim could be premised upon future harm to health from exposure to environmental tobacco smoke).

44
Estelle v. Gamblegreen
scotus · 1976 · cited in 6 Pennsylvania opinions naming this issue, 2003–2022
2 sentences

2022The Supreme Court of the United States has thus held that the denial of medical care to a prison inmate constitutes a violation of the Eighth Amendment where it amounts to “deliberate indifference to serious medical needs of prisoners.” Id. at 104 . 6 In his Eighth Amendment claim, Rokita asserts that, by refusing to provide him with the opportunity to receive MAT for his substance use disorder, the Department is denying him medical care.

2019The Petition merely indicates, they argue, that, “at some unspecified date[s] and time[s]” Thomas suffered a seizure and “a severe electrical burn for which he received substandard emergency . . . [and] follow-up treatment.” (PO ¶¶ 39, 50.) Such vague allegations, which do not connect the alleged substandard 7 medical treatment to any of the named Employee Respondents, none of whom are medical staff, they argue, do not meet the applicable pleading standard for an Eighth Amendment claim under Estelle v. Gamble, 429 U.S. 97, 103-04 (1976).

36
Harmelin v. Michigangreen
scotus · 1991 · cited in 5 Pennsylvania opinions naming this issue, 2010–2025
2 sentences

2022See Jones, 141 S.Ct. at 1322 (“this case does not properly present — and thus we do not consider — any as-applied Eighth Amendment claim of disproportionality regarding Jones’s sentence.”), citing Harmelin v. Michigan, 501 U.S. 957 , 996–1009 (1991) (Kennedy, J., concurring in part and concurring in judgment).

2017The focus of an Eighth Amendment challenge is whether the sentence imposed is “grossly disproportionate to a crime.” Spells, supra, 612 A.2d at 463 , quoting Harmelin v. Michigan, 501 U.S. 957, 1005 (1991).

35
Kretchmar v. Commonwealth, Department of Correctionsgreen
pacommwct · 2003 · cited in 3 Pennsylvania opinions naming this issue, 2019–2025
2 sentences

2025As we held in Dukes v. Pennsylvania Department of Corrections (Pa. Cmwlth, No. 281 M.D. 2020, filed February 17, 2021), slip op. at 8, when the pleading itself shows an inmate received medical attention, the allegations “do not rise to the level of an Eighth Amendment violation based on deliberate indifference.” See also Kretchmar, 831 A.2d at 799-800 (“Even a cursory review of the [p]etition reveals that [the p]etitioner receive[d] extensive medical attention while in prison.”).

2025As we held in Dukes v. Pennsylvania Department of Corrections (Pa. Cmwlth, No. 281 M.D. 2020, filed February 17, 2021), slip op. at 8, when the pleading itself shows an inmate received medical attention, the allegations “do not rise to the level of an Eighth Amendment violation based on deliberate indifference.” See also Kretchmar, 831 A.2d at 799-800 (“Even a cursory review of the [p]etition reveals that [the p]etitioner receive[d] extensive medical attention while in prison.”).

33
Commonwealth v. Spellsgreen
pasuperct · 1992 · cited in 3 Pennsylvania opinions naming this issue, 2017–2025
2 sentences

2025When an appellant presents an Eighth Amendment challenge to his sentence, this Court applies the following analysis: In Commonwealth v. Spells, [] 612 A.2d 458, 462 (1992) (en banc), this Court applied the three-prong test for Eighth Amendment proportionality review set forth by the United States Supreme Court in Solem v. Helm, 463 U.S. 277 [] (1983): [A] court’s proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdict

2025When an appellant presents an Eighth Amendment challenge to his sentence, this Court applies the following analysis: In Commonwealth v. Spells, [] 612 A.2d 458, 462 (1992) (en banc), this Court applied the three-prong test for Eighth Amendment proportionality review set forth by the United States Supreme Court in Solem v. Helm, 463 U.S. 277 [] (1983): [A] court’s proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdict

23
Commonwealth v. Succigreen
pasuperct · 2017 · cited in 2 Pennsylvania opinions naming this issue, 2021–2025
2 sentences

2025See Commonwealth v. Succi, 173 A.3d 269, 284-85 (observing that alleged Eighth Amendment violation does not necessarily constitute challenge to legality of sentence). - 27 - J-A26044-25 excessive and that the trial court failed to consider his individual circumstances and mitigating factors. “[S]entencing is vested in the sound discretion of the sentencing court, and we shall not disturb a sentence absent a manifest abuse of discretion.” Commonwealth v. Schroat, 272 A.3d 523, 527 (Pa.Super 2022).

2021See Succi, 173 A.3d at 285 (finding Eighth Amendment challenge to sentence waived where challenge implicated discretionary aspects of sentence rather than legality of sentence).

22
Commonwealth v. Bakergreen
pa · 2013 · cited in 2 Pennsylvania opinions naming this issue, 2016–2023
2 sentences

2016Baker includes a review of High Court Eighth Amendment proportionality decisions illustrating that successful challenges to recidivist sentencing schemes and non-capital sentences are “extremely rare.” Id. at 1048-49. 4 Justice Kennedy’s understanding of the first prong of the Solem test as a threshold hurdle in establishing an Eighth Amendment violation has been recently cited with approval by the High Court as well.

2016Baker includes a review of High Court Eighth Amendment proportionality decisions illustrating that successful challenges to recidivist sentencing schemes and non-capital sentences are “extremely rare.” Id. at 1048-49. 4 Justice Kennedy’s understanding of the first prong of the Solem test as a threshold hurdle in establishing an Eighth Amendment violation has been recently cited with approval by the High Court as well.

22
Jones v. Mississippigreen
scotus · 2021 · cited in 2 Pennsylvania opinions naming this issue, 2021–2022
2 sentences

2022See Jones, 141 S.Ct. at 1322 (“this case does not properly present — and thus we do not consider — any as-applied Eighth Amendment claim of disproportionality regarding Jones’s sentence.”), citing Harmelin v. Michigan, 501 U.S. 957 , 996–1009 (1991) (Kennedy, J., concurring in part and concurring in judgment).

2022See Jones, 141 S.Ct. at 1322 (“this case does not properly present — and thus we do not consider — any as-applied Eighth Amendment claim of disproportionality regarding Jones’s sentence.”), citing Harmelin v. Michigan, 501 U.S. 957 , 996–1009 (1991) (Kennedy, J., concurring in part and concurring in judgment).

22
Commonwealth v. 1997 Chevroletgreen
pacommwct · 2014 · cited in 2 Pennsylvania opinions naming this issue, 2017–2017
2 sentences

2017Reconciling these decisions, the Commonwealth Court found that, for a civil forfeiture brought under the Forfeiture Act to survive an Eighth Amendment challenge, the Commonwealth must show, initially, that the forfeitable property was the instrumentality of the offense. 1997 Chevrolet, 106 A.3d at 858-59, 866 .

2017Reconciling these decisions, the Commonwealth Court found that, for a civil forfeiture brought under the Forfeiture Act to survive an Eighth Amendment challenge, the Commonwealth must show, initially, that the forfeitable property was the instrumentality of the offense. 1997 Chevrolet, 106 A.3d at 858-59, 866 .

22
Von Hofe v. United Statesgreen
ca2 · 2007 · cited in 3 Pennsylvania opinions naming this issue, 2017–2023
2 sentences

2023See, e.g., Von Hofe v. United States, 492 F.3d 175, 189 (2d Cir. 2007) (co-owner knew marijuana was being cultivated in the basement of her home and was convicted of possession of marijuana but because she did not know her husband was distributing the marijuana, the forfeiture of her half interest in the house was held to impose an excessive and unconstitutional fine). 11 The underlying offense was a long-term drug trafficking operation, where Gavlak entered into a conspiracy with her children and son-in-law to sell large amounts of cocaine over a two-year period.

2023See, e.g., Von Hofe v. United States, 492 F.3d 175, 189 (2d Cir. 2007) (co-owner knew marijuana was being cultivated in the basement of her home and was convicted of possession of marijuana but because she did not know her husband was distributing the marijuana, the forfeiture of her half interest in the house was held to impose an excessive and unconstitutional fine). 11 The underlying offense was a long-term drug trafficking operation, where Gavlak entered into a conspiracy with her children and son-in-law to sell large amounts of cocaine over a two-year period.

13
Graham v. Floridagreen
scotus · 2010 · cited in 3 Pennsylvania opinions naming this issue, 2011–2016
2 sentences

2016“A court must begin by comparing the gravity of the offense and the severity of the sentence.” Graham v. Florida, 560 U.S. 48, 60-61 , 130 S.Ct. 2011, 2022 , 176 L.Ed.2d 825 (2010).

2016“A court must begin by comparing the gravity of the offense and the severity of the sentence.” Graham v. Florida, 560 U.S. 48, 60-61 , 130 S.Ct. 2011, 2022 , 176 L.Ed.2d 825 (2010).

13
Neitzke v. Williamsred
scotus · 1989 · cited in 2 Pennsylvania opinions naming this issue, 2024–2025
2 sentences

2025An action is frivolous if it “lacks an arguable basis either in law or in fact.” Pa.R.C[iv].P. 240(j) (quoting Neitzke v. Williams, 490 U.S. 319, 325 (1989)). [Inmate’s] action lacks an arguable basis in law because he is unable to meet the requirements to succeed on this Eighth Amendment claim.

2025An action is frivolous if it “lacks an arguable basis either in law or in fact.” Pa.R.C[iv].P. 240(j) (quoting Neitzke v. Williams, 490 U.S. 319, 325 (1989)). [Inmate’s] action lacks an arguable basis in law because he is unable to meet the requirements to succeed on this Eighth Amendment claim.

12
Tillery v. Owensgreen
· 1990 · cited in 2 Pennsylvania opinions naming this issue, 2021–2023
2 sentences

2023An Eighth Amendment violation can be asserted where an inmate is deprived of “‘the minimal civilized measure of life’s necessities.’” Lopez v. Pennsylvania Department of Corrections, 119 A.3d 1081, 1090 (Pa. Cmwlth. 2015) (quoting Tillery v. Owens, 907 F.2d 418, 426 (3d Cir. 1990)).

2023An Eighth Amendment violation can be asserted where an inmate is deprived of “‘the minimal civilized measure of life’s necessities.’” Lopez v. Pennsylvania Department of Corrections, 119 A.3d 1081, 1090 (Pa. Cmwlth. 2015) (quoting Tillery v. Owens, 907 F.2d 418, 426 (3d Cir. 1990)).

12
Andrew v. Whitegreen
scotus · 2025 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
2 sentences

2026Cf. Andrew v. White, 604 U.S. 86, 95 (2025) (per curiam) (reaffirming that “certain principles are fundamental enough that when new factual permutations arise, the necessity to apply the earlier rule will be beyond doubt”) (citations omitted); id. at 94– 95 (recognizing the overlap between general legal principle underlying state prisoner’s Fourteenth Amendment due process claim and “the Eighth Amendment principle that a sentence may not be grossly disproportionate to the offense”) (citation omitted). [J-31-2025] [MO: Wecht, J.] - 5 378, 390–393 (2005); Wiggins, 539 U.S. at 534–538; Williams,

2026Cf. Andrew v. White, 604 U.S. 86, 95 (2025) (per curiam) (reaffirming that “certain principles are fundamental enough that when new factual permutations arise, the necessity to apply the earlier rule will be beyond doubt”) (citations omitted); id. at 94– 95 (recognizing the overlap between general legal principle underlying state prisoner’s Fourteenth Amendment due process claim and “the Eighth Amendment principle that a sentence may not be grossly disproportionate to the offense”) (citation omitted). [J-31-2025] [MO: Wecht, J.] - 5 378, 390–393 (2005); Wiggins, 539 U.S. at 534–538; Williams,

11
Chance v. Armstronggreen
ca2 · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
11
Com. v. Schroat, S.green
pasuperct · 2022 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
11
Commonwealth v. Lankfordgreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Mourygreen
pasuperct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Lopez v. Pa. Department of Correctionsgreen
pacommwct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Burrell v. Hampshire Countygreen
ca1 · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
11
Miller v. Alabamagreen
scotus · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
11
Robert A. Gaudreault v. Municipality of Salem, Massachusettsgreen
ca1 · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
11
Bullock v. Horngreen
pacommwct · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
11
Perry v. Roygreen
ca1 · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
11
Lamb v. Norwoodgreen
ca10 · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
11
Mark A. Campbell v. Kevin Kallasgreen
ca7 · 2019 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
11
Kosilek v. Spencergreen
ca1 · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
11
Commonwealth v. Oldsgreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
11
Discover Bank v. Royalgreen
ri · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
11
Commonwealth v. Greengreen
pasuperct · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
11
Yount v. Pennsylvania Department of Correctionsgreen
pa · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
11
Commonwealth v. 502-504 Gordon Streetgreen
pacommwct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Castrogreen
pasuperct · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Colon-Plazagreen
pasuperct · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. One 1985 Dark Blue Mercedes Benz Cargreen
pa · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Spruillgreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Battsgreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Commonwealth v. Trivignogreen
pa · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (38)

CaseCitedYears
Payne v. Tennessee green
scotus · 1991
2 sentences

2026The Opinion Announcing the Judgment of the Court did not accept that Article I, Section 13 claims required lockstep devotion to federal law interpreting the Eighth Amendment, as the Court could have refrained from further state constitutional analysis by citing Payne v. Tennessee, 501 U.S. 808 (1991), as dispositive of the Eighth Amendment claim.

2026The Opinion Announcing the Judgment of the Court did not accept that Article I, Section 13 claims required lockstep devotion to federal law interpreting the Eighth Amendment, as the Court could have refrained from further state constitutional analysis by citing Payne v. Tennessee, 501 U.S. 808 (1991), as dispositive of the Eighth Amendment claim.

42013–2026
Zant v. Stephens green
scotus · 1983
2 sentences

2014The Fletcher Court noted, preliminarily, that “to survive an Eighth Amendment challenge ‘an aggravating circumstance must genuinely narrow the class of persons eligible for the death penalty and must reasonably justify the imposition of a more severe sentence on the defendant compared to others found guilty of murder.’ ” Id. at 428, 861 A.2d at 912 (indirectly quoting Zant v. Stephens, 462 U.S. 862, 877 , 103 S.Ct. 2733, 2742 , 77 L.Ed.2d 235 (1983)).

2014The Fletcher Court noted, preliminarily, that “to survive an Eighth Amendment challenge ‘an aggravating circumstance must genuinely narrow the class of persons eligible for the death penalty and must reasonably justify the imposition of a more severe sentence on the defendant compared to others found guilty of murder.’ ” Id. at 428, 861 A.2d at 912 (indirectly quoting Zant v. Stephens, 462 U.S. 862, 877 , 103 S.Ct. 2733, 2742 , 77 L.Ed.2d 235 (1983)).

32002–2014
Caldwell v. Mississippi green
scotus · 1985
2 sentences

2019The United States Supreme Court granted certiorari to address "whether a capital sentence is valid when the sentencing jury is led to believe that responsibility for determining the appropriateness of a death sentence rests not with the jury but with the appellate court which later reviews the case." Caldwell , 472 U.S. at 323 , 105 S.Ct. 2633 .

2019The United States Supreme Court granted certiorari to address "whether a capital sentence is valid when the sentencing jury is led to believe that responsibility for determining the appropriateness of a death sentence rests not with the jury but with the appellate court which later reviews the case." Caldwell , 472 U.S. at 323 , 105 S.Ct. 2633 .

22019–2019
Wilson v. Seiter green
scotus · 1991
2 sentences

2018Wilson v. Seiter, 501 U.S. 294 . . . (1991).

2018Wilson v. Seiter, 501 U.S. 294 . . . (1991).

22014–2018
Commonwealth v. Real Property & Improvements Commonly Known as 5444 Spruce Street green
pa · 2003
2 sentences

2017Thus, the Court was not relying upon the understanding of “instrumentality” as that term would develop in subsequent cases, but was deeming the property at issue — a mobile home and auto body shop — not to be “contraband,” and, thus, subject to an Eighth Amendment challenge. [J-68A-2016 and J-68B-2016] - 45 further, we traced the high Court’s pre-Bajakajian decisions, discerning a pointed distinction between forfeitures which were upheld because they exhibited a significant relationship between the property and the crime, and those where the property forfeited was not significantly related to

2017Thus, the Court was not relying upon the understanding of “instrumentality” as that term would develop in subsequent cases, but was deeming the property at issue — a mobile home and auto body shop — not to be “contraband,” and, thus, subject to an Eighth Amendment challenge. [J-68A-2016 and J-68B-2016] - 45 further, we traced the high Court’s pre-Bajakajian decisions, discerning a pointed distinction between forfeitures which were upheld because they exhibited a significant relationship between the property and the crime, and those where the property forfeited was not significantly related to

22017–2017
Rhodes v. Chapman green
scotus · 1981
2 sentences

2014Although correctional institutions are by their very nature restrictive and even harsh, the Eighth Amendment requires that the conditions of confinement do not include “unnecessary and wanton” inflictions of pain that are “totally without pe-nological justification.” Rhodes v. Chapman, 452 U.S. 337, 346 , 101 S.Ct. 2392, 2399 , 69 L.Ed.2d 59 (1981).

2014Although correctional institutions are by their very nature restrictive and even harsh, the Eighth Amendment requires that the conditions of confinement do not include “unnecessary and wanton” inflictions of pain that are “totally without pe-nological justification.” Rhodes v. Chapman, 452 U.S. 337, 346 , 101 S.Ct. 2392, 2399 , 69 L.Ed.2d 59 (1981).

21986–2014
Roper v. Simmons green
scotus · 2005
2 sentences

2011See Graham v. Florida, ___ U.S. ___, 130 S.Ct. 2011 , 176 L.Ed.2d 825 (2010) (Eighth Amendment prohibits sentence of life without parole for juveniles (defined as individuals under 18) who did not commit homicide); Roper v. Simmons, 543 U.S. 551 , 125 S.Ct. 1183 , 161 L.Ed.2d 1 (2005) (Eighth Amendment prohibits imposition of capital punishment for offenders committing their crimes prior to age 18) Those over eighteen get no benefit from these constitutional decisions, irrespective of their subjective "psychological and emotional age and level of maturity." [32] The statements by Judge Mihalic

2011See Graham v. Florida, ___ U.S. ___, 130 S.Ct. 2011 , 176 L.Ed.2d 825 (2010) (Eighth Amendment prohibits sentence of life without parole for juveniles (defined as individuals under 18) who did not commit homicide); Roper v. Simmons, 543 U.S. 551 , 125 S.Ct. 1183 , 161 L.Ed.2d 1 (2005) (Eighth Amendment prohibits imposition of capital punishment for offenders committing their crimes prior to age 18) Those over eighteen get no benefit from these constitutional decisions, irrespective of their subjective "psychological and emotional age and level of maturity." [32] The statements by Judge Mihalic

22008–2011
Commonwealth v. Waters green
pa · 1984
2 sentences

1992Id., 334 Pa.Super. at 525-26 , 483 A.2d at 861 .

1992Id., 334 Pa.Super. at 525-26 , 483 A.2d at 861 .

21985–1992
Wiggins v. Smith, Warden green
scotus · 2003
1 sentence

2026Cf. Andrew v. White, 604 U.S. 86, 95 (2025) (per curiam) (reaffirming that “certain principles are fundamental enough that when new factual permutations arise, the necessity to apply the earlier rule will be beyond doubt”) (citations omitted); id. at 94– 95 (recognizing the overlap between general legal principle underlying state prisoner’s Fourteenth Amendment due process claim and “the Eighth Amendment principle that a sentence may not be grossly disproportionate to the offense”) (citation omitted). [J-31-2025] [MO: Wecht, J.] - 5 378, 390–393 (2005); Wiggins, 539 U.S. at 534–538; Williams,

12026–2026
Williams v. Taylor green
scotus · 2000
1 sentence

2026Cf. Andrew v. White, 604 U.S. 86, 95 (2025) (per curiam) (reaffirming that “certain principles are fundamental enough that when new factual permutations arise, the necessity to apply the earlier rule will be beyond doubt”) (citations omitted); id. at 94– 95 (recognizing the overlap between general legal principle underlying state prisoner’s Fourteenth Amendment due process claim and “the Eighth Amendment principle that a sentence may not be grossly disproportionate to the offense”) (citation omitted). [J-31-2025] [MO: Wecht, J.] - 5 378, 390–393 (2005); Wiggins, 539 U.S. at 534–538; Williams,

12026–2026
Solem v. Helm red
scotus · 1983
2 sentences

2025When an appellant presents an Eighth Amendment challenge to his sentence, this Court applies the following analysis: In Commonwealth v. Spells, [] 612 A.2d 458, 462 (1992) (en banc), this Court applied the three-prong test for Eighth Amendment proportionality review set forth by the United States Supreme Court in Solem v. Helm, 463 U.S. 277 [] (1983): [A] court’s proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdict

2025When an appellant presents an Eighth Amendment challenge to his sentence, this Court applies the following analysis: In Commonwealth v. Spells, [] 612 A.2d 458, 462 (1992) (en banc), this Court applied the three-prong test for Eighth Amendment proportionality review set forth by the United States Supreme Court in Solem v. Helm, 463 U.S. 277 [] (1983): [A] court’s proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdict

12025–2025
Hiko Energy, LLC v. Pa. Pub. Util. Comm'n green
pa · 2019
2 sentences

2025HIKO Energy, 209 A.3d at 263 .

2025HIKO Energy, 209 A.3d at 263 .

12025–2025
Monmouth County Correctional Institutional Inmates v. William Lanzaro green
ca3 · 1987
2 sentences

2025Chance v. Armstrong, 143 F.3d 698, 702 (2d Cir. 1998); Monmouth C[nty.] Corr[.] Inst[.] Inmates v. Lanzaro, 834 F.2d 326 , 347 (3d Cir. 1987). *** In addition to satisfying the objective component of an Eighth Amendment claim, a prisoner must also allege acts or omissions that evidence deliberate indifference on the part of prison officials in order to state a cognizable claim that the prisoner’s constitutional right to be free from cruel and unusual punishment has been violated.

2025Chance v. Armstrong, 143 F.3d 698, 702 (2d Cir. 1998); Monmouth C[nty.] Corr[.] Inst[.] Inmates v. Lanzaro, 834 F.2d 326 , 347 (3d Cir. 1987). *** In addition to satisfying the objective component of an Eighth Amendment claim, a prisoner must also allege acts or omissions that evidence deliberate indifference on the part of prison officials in order to state a cognizable claim that the prisoner’s constitutional right to be free from cruel and unusual punishment has been violated.

12025–2025
United States v. Michael Walker green
ca3 · 2007
12025–2025
Hutto v. Davis green
scotus · 1982
2 sentences

2025Similarly, in Huto v. Davis, [ 454 U.S. 370 (1982),] the U.S. Supreme [rejected] an Eighth Amendment challenge to a 40-year sentence for the crime of possessing nine ounces (255 grams) of marijuana. [Id. at 371-72.] Certainly, [Appellant’s] sentence is less severe than the [f]ederal standard for Eighth Amendment challenges. [Appellant’s] … sentence of 21 to 42 years is not cruel or unusual punishment.

2025Similarly, in Huto v. Davis, [ 454 U.S. 370 (1982),] the U.S. Supreme [rejected] an Eighth Amendment challenge to a 40-year sentence for the crime of possessing nine ounces (255 grams) of marijuana. [Id. at 371-72.] Certainly, [Appellant’s] sentence is less severe than the [f]ederal standard for Eighth Amendment challenges. [Appellant’s] … sentence of 21 to 42 years is not cruel or unusual punishment.

12025–2025
Shoul v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pa · 2017
12024–2024
Bennett v. Beard green
pacommwct · 2007
12024–2024
G. Watkins v. PA DOC, Secretary, John Wetzel, Superintendent Robert Gilmore green
pacommwct · 2018
12023–2023
Kiman v. New Hampshire Department of Corrections green
ca1 · 2006
12022–2022
STONE & EDWARDS INS. v. Dept. of Ins. green
pacommwct · 1992
12022–2022
Platt v. Brockenborough green
paed · 2007
12022–2022
Smith v. Mensinger green
ca3 · 2002
12022–2022
Monell v. New York City Dept. of Social Servs. green
scotus · 1978
12022–2022
Alexander v. Weiner green
mad · 2012
12022–2022
SEIU Healthcare Pennsylvania v. Commonwealth green
pa · 2014
12022–2022
Griffin v. Vaughn green
ca3 · 1997
12021–2021
Anthony Dixon v. Salvador A. Godinez, Theopolis Smith, Thomas P. Roth & Dennis Jennings green
ca7 · 1997
12021–2021
Lopez v. Wetzel neutral
pa · 2016
12021–2021
Scott Gibson v. Bryan Collier green
ca5 · 2019
12020–2020
Smith v. Pennsylvania Employees Benefit Trust Fund green
pacommwct · 2006
12019–2019
Justice Allah v. Michele Ricci green
ca3 · 2013
12019–2019
Commonwealth v. Dougherty green
pa · 2004
12018–2018
Commonwealth v. Little green
pasuperct · 1998
12017–2017
Commonwealth v. Yasipour green
pasuperct · 2008
12017–2017
Commonwealth v. 1997 Chevrolet & Contents Seized From Young green
pa · 2017
12017–2017
Charles M. KEENAN, Plaintiff-Appellant, v. Frank HALL, Director Oregon Department of Corrections, Et Al., Defendants-Appellees green
ca9 · 1996
12015–2015
Charles M. Keenan v. Frank Hall, Director Oregon Department of Corrections green
ca9 · 1998
12015–2015
Commonwealth v. Wilson green
pasuperct · 2003
12014–2014

Statutes the citing opinions construe

USC § 42u.s.c.1983 (18) PA § 42 Pa. Cons. Stat. § 9711 (15) PA § 18 Pa. Cons. Stat. § 2502 (10) PA § 42 Pa. Cons. Stat. § 9543 (10) PA § 18 Pa. Cons. Stat. § 1102 (8) PA § 18 Pa. Cons. Stat. § 1102.1 (8) PA § 42 Pa. Cons. Stat. § 9545 (6) PA § 61 Pa. Cons. Stat. § 6137 (6) PA § 18 Pa. Cons. Stat. § 7512 (5) PA § 42 Pa. Cons. Stat. § 761 (5) PA § 42 Pa. Cons. Stat. § 9546 (5) PA § 42 Pa. Cons. Stat. § 9718.2 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 305 (1983–2026) TX 222 (1988–2026) IL 124 (1981–2026) FL 85 (1981–2026) PA 80 (1985–2026) VA 62 (1983–2026) OH 48 (1999–2025) KS 43 (2001–2026) MS 42 (1986–2025) WA 37 (1983–2023) OR 35 (1992–2025) AZ 33 (1978–2024) TN 30 (1994–2022) MA 30 (1976–2026) CO 29 (1990–2026) MI 28 (1984–2025) IA 28 (1999–2022) ID 27 (1983–2024) SD 24 (1980–2024) AL 24 (1984–2026) NY 23 (1974–2026) OK 22 (1987–2020) MO 21 (1993–2023) IN 20 (1979–2024) NC 20 (1991–2025) NJ 20 (1983–2022) GA 18 (1992–2026) KY 17 (2003–2024) MD 17 (1972–2026) CT 17 (1995–2022) WI 14 (1994–2026) AR 14 (1996–2026) LA 13 (1987–2025) DE 13 (1988–2022) DC 13 (1975–2019) UT 13 (1995–2025) SC 12 (1991–2025) WY 12 (1986–2023) NE 11 (1999–2024) NM 9 (1991–2019) MN 8 (1976–2024) MT 8 (1996–2022) WV 7 (1994–2023) VT 6 (1998–2018) NV 6 (1979–2020) ND 6 (1992–2022) ME 5 (1987–2015) AK 4 (2010–2022) VI 3 (2003–2012) NH 3 (1980–2013) RI 3 (2004–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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