Lockyer v. Andrade
The Supreme Court reversed a federal appeals court ruling that had thrown out a career criminal's sentence of 50 years to life for stealing about $150 worth of videotapes under California's three-strikes law.
The Court held that under the federal habeas statute, a state court's decision upholding the sentence was not unreasonable enough to justify federal intervention, even though the Court's own precedents on when long sentences violate the Constitution were unclear.
“Rather, that application must be objectively unreasonable.”
The Court's standard for when a federal court may override a state court's legal ruling in habeas cases.
How it got here: A California appeals court upheld the sentence; a federal district court denied habeas relief; the Ninth Circuit reversed and granted the writ; California asked the Supreme Court to review that reversal.
The Case in Depth
What happened
Leandro Andrade, a longtime drug addict with a history of burglary and drug convictions, stole videotapes worth about $150 from two Kmart stores two weeks apart. Because he had prior "strikes," California's three-strikes law required a judge to sentence him to two consecutive terms of 25 years to life, for a total of 50 years to life in prison.
The question before the Court
Could a federal court overturn a 50-years-to-life "three strikes" sentence for stealing videotapes, given the strict limits Congress placed on federal habeas review of state convictions?
The Court's answer
No — the Court ruled that a federal court could not overturn Andrade's sentence through habeas corpus, because the federal habeas statute only allows relief when a state court's decision was contrary to, or an unreasonable application of, clearly established Supreme Court law. The Court's own precedents on when long sentences become unconstitutionally disproportionate were themselves unclear and inconsistent, establishing only a narrow rule that gross disproportionality violates the Eighth Amendment in extremely rare, extreme cases.
Because that rule's boundaries were so vague, the state appeals court's decision to uphold the sentence by relying on a similar older case was not objectively unreasonable, even if it might have been debatable or even wrong on the merits. The Ninth Circuit had improperly applied its own "clear error" standard instead of the more deferential standard Congress required, so its decision granting relief was reversed.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The decision makes it harder for federal courts to second-guess state sentences under habeas corpus, especially in areas like three-strikes sentencing where Supreme Court precedent is muddled. People sentenced under tough repeat-offender laws face a steep, deferential standard when trying to challenge those sentences in federal court.
What changes now
The Ninth Circuit's grant of habeas relief is reversed, meaning Andrade's 50-years-to-life sentence stands. The decision does not prevent Andrade from separately pursuing state-court relief under a later California Supreme Court ruling allowing judges to dismiss strikes count-by-count. This is a final merits decision on the narrow federal habeas question, not a ruling that three-strikes sentences are always constitutional.
What this does not decide
The Court did not decide whether Andrade's sentence actually violates the Eighth Amendment on direct review — it decided only that the state court's contrary conclusion was not unreasonable enough to justify federal habeas relief under the deferential AEDPA standard. Whether the sentence is fair as a policy matter was left open.
Concurrences and dissents
Dissent — Justice Souter
“If Andrade's sentence is not grossly disproportionate, the principle has no meaning.”Souter's central objection that the majority drained the disproportionality rule of any real force.
Justice Souter argued Andrade's sentence was grossly disproportionate and that the state court's ruling was not just wrong but unreasonable. He said the facts matched Solem v. Helm closely, since Andrade's 50-year sentence effectively meant life without parole for two minor, related thefts. He also argued the state's own incapacitation rationale could not justify doubling the sentence for a second theft that didn't show Andrade had become more dangerous.
How the Court got there
The legal reasoning, step by step
- The Court explained that a federal habeas statute passed by Congress, AEDPA, blocks federal courts from overturning a state court's ruling unless that ruling was contrary to, or an unreasonable application of, clearly established Supreme Court law — a deliberately narrow and deferential standard.
- The Court reviewed its own precedents on long prison sentences and found they only clearly established one general rule: a sentence can violate the Eighth Amendment's ban on cruel and unusual punishment if it is grossly disproportionate to the crime, but only in extremely rare, extreme cases.
- Because the Court's precedents themselves did not draw a clear or consistent line for when a term-of-years sentence crosses that threshold, the state appeals court's decision to rely on an older case involving a similarly harsh sentence was not contrary to clearly established law.
- The Court rejected the Ninth Circuit's approach of first deciding independently whether the sentence was wrong and then asking whether that error was 'clear,' explaining that conflating ordinary error with unreasonableness gives state courts too little deference under the habeas statute.
- Applying the correct, more deferential standard, the Court concluded it was not objectively unreasonable for the state court to conclude that the unclear proportionality principle permitted Andrade's sentence, so federal habeas relief was unavailable.
Doctrinal impact
Cases affected by this decision
Distinguishes Solem v. Helm (463 U.S. 277)
The Court found Andrade's case not materially identical to Solem's facts, so it did not control the outcome.
Reaffirms Rummel v. Estelle (445 U.S. 263)
The Court treated Rummel as good law that a state court could reasonably rely on to uphold a long sentence.