The first and only case in which the Supreme Court has invalidated a prison sentence because of its length was Solem v. Helm, 463 U.S. at 290. See Erwin Chemerinsky, the Constitution and Punishment, 56 Stan. L. Rev. 1049, 1058 (2004) (noting that "Solem v. Helm remains the only case in which the Supreme Court has found a prison sentence to be grossly disproportionate"). The defendant in Solem had been sentenced to life imprisonment without parole for writing a "no account" check for $ 100. 463 U.S. at 281. The defendant previously had been convicted of six nonviolent felonies, including third-degree burglary (three times), obtaining money under false pretenses, grand larceny, and third-offense driving while intoxicated. Id. at 279-80. The Court concluded that the sentence of life imprisonment without parole was "significantly disproportionate to [the] crime, and . . . therefore prohibited by the Eighth Amendment." Id. at 303. In Solem, the Court's proportionality analysis was "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 jurisdiction; (iii) the sentences imposed for commission of the same crime in other jurisdictions." Id. at 292. While characterizing the first of the three factors as one that "a court must consider," in discussing the other factors the Court stated only that "it may be helpful" to apply the second and that "courts may find it useful" to apply the third. Id. at 291. Solem remains the only case in which the United States Supreme Court declared a sentence unconstitutional based on its length. Since then, it has twice upheld such sentences, but without agreement on a rationale. Eight years after Solem, the Supreme Court decided Harmelin v. Michigan, 501 U.S. 957, 115 L. Ed. 2d 836, 111 S. Ct. 2680 (1991).