In People v. Dillon (1983) 34 Cal.3d 441, the California Supreme Court reaffirmed the rule it adopted in In re Lynch (1972) 8 Cal.3d 410 that "a statutory punishment may violate the constitutional prohibition not only if it is inflicted by a cruel or unusual method, but also if it is grossly disproportionate to the offense for which it is imposed." (Dillon, supra, 34 Cal.3d at p. 478, citing Lynch, supra, 8 Cal.3d at pp. 423-424.) The California high state court has adopted three "techniques" (the Lynch techniques) that California courts have used to determine whether a particular sentence is so grossly disproportionate to the offense for which it is imposed that it constitutes cruel and unusual punishment within the meaning of the Eighth Amendment. (Dillon, supra, 34 Cal.3d at p. 479 "In each such decision the court used certain 'techniques' identified in Lynch, supra, 8 Cal.3d at pages 425-429, to aid in determining proportionality".) The first Lynch technique is an examination of the "nature of the offense and/or the offender, with particular regard to the degree of danger both present to society." (Lynch, supra, 8 Cal.3d at p. 425; see also Dillon, supra, 34 Cal.3d at p. 479.) In conducting the inquiry into the "nature of the offense," the courts "are to consider not only the offense in the abstract -- i.e., as defined by the Legislature -- but also 'the facts of the crime in question' -- i.e., the totality of the circumstances surrounding the commission of the offense in the case at bar, including such factors as its motive, the way it was committed, the extent of the defendant's involvement, and the consequences of his acts." (Dillon, supra, 34 Cal.3d at p. 479.) The related inquiry into the "nature of the offender" is focused "on the particular person before the court, and asks whether the punishment is grossly disproportionate to the defendant's individual culpability as shown by such factors as his age, prior criminality, personal characteristics, and state of mind." (Ibid.) Under the second Lynch technique, the courts "compare the challenged penalty with the punishments prescribed in the same jurisdiction for different offenses which, by the same test, must be deemed more serious." (Lynch, supra, 8 Cal.3d at p. 426.) The last Lynch technique employed by California courts is a comparison of the challenged punishment with punishments for the same offense in other jurisdictions. (Lynch, supra, 8 Cal.3d at p. 436.) Ultimately, the test to be applied in California for determining whether a particular punishment violates the California constitutional prohibition against cruel or unusual punishment is whether, "although not cruel or unusual in its method, it is so disproportionate to the crime for which it is inflicted that it shocks the conscience and offends fundamental notions of human dignity.'" (Dillon, supra, 34 Cal.3d at p. 478, quoting Lynch, supra, 8 Cal.3d at p. 424.)