"The Eighth Amendment, which forbids cruel and unusual punishments, contains a 'narrow proportionality principle' that 'applies to noncapital sentences.' " (Ewing v. California (2003) 538 U.S. 11, 20, citing Harmelin v. Michigan (1991) 501 U.S. 957, 996-997.) " 'The Eighth Amendment does not require strict proportionality between crime and sentence. Rather, it forbids only extreme sentences that are "grossly disproportionate" to the crime.' " (Ewing, supra, at p. 23.) In Harmelin, the defendant was convicted of possessing 672 grams of cocaine and sentenced to a mandatory term of life in prison without possibility of parole. He claimed that his sentence constituted cruel and unusual punishment in part because it was " 'significantly disproportionate' " to the crime he committed. (Harmelin, supra, 501 U.S. at p. 961.) The Supreme Court found that "the Michigan Legislature could with reason conclude that the threat posed to the individual and society by possession of this large an amount of cocaine--in terms of violence, crime, and social displacement--is momentous enough to warrant the deterrence and retribution of a life sentence without parole." (Id. at p. 1003.) The court further held that "intrajurisdictional and interjurisdictional analyses are appropriate only in the rare case in which a threshold comparison of the crime committed and the sentence imposed leads to an inference of gross proportionality" and that, "in light of the gravity of the defendant's offense, a comparison of his crime with his sentence does not give rise to an inference of gross disproportionality." (Id. at p. 1005) In Ewing, the defendant was convicted of grand theft of three golf clubs worth $ 399 each. The defendant's criminal history spanned 1984 to 1998 and included misdemeanor and felony convictions for petty theft, auto theft, battery, burglary, robbery, possession of drugs, trespass, and unlawful possession of a firearm. The trial court imposed a life term under the Three Strikes law. (Ewing, supra, 538 U.S. at pp. 17-20.) The Supreme Court explained that in enacting the Three Strikes law, the California Legislature "made a judgment that protecting the public safety requires incapacitating criminals who have already been convicted of at least one serious or violent crime. Nothing in the Eighth Amendment prohibits California from making that choice." (Id. at p. 25.) In addressing the gravity of the offense compared to the harshness of the penalty, the court emphasized that the gravity of the defendant's offense included not only his current felony, but also his history of having been convicted of at least two violent or serious felonies. (Id. at pp. 28-29.) "In imposing a three strikes sentence, the State's interest is not merely punishing the offense of conviction, or the 'triggering' offense: 'It is in addition the interest . . . in dealing in a harsher manner with those who by repeated criminal acts have shown that they are simply incapable of conforming to the norms of society as established by its criminal law.' " (Id. at p. 29.) The court found that "Ewing's sentence is justified by the State's public-safety interest in incapacitating and deterring recidivist felons, and amply supported by his own long, serious criminal record." (Id. at pp. 29-30.) Therefore, the court held that "Ewing's sentence of 25 years to life in prison, imposed for the offense of felony grand theft under the three strikes law, is not grossly disproportionate and therefore does not violate the Eighth Amendment's prohibition on cruel and unusual punishments." (Id. at pp. 30-31.)