825 (2010). Broom’s challenge does not fit neatly into either category. {¶ 37} In noncapital cases, the Eighth Amendment proportionality principle is narrow and “ ‘forbids only extreme sentences’ ” that are grossly disproportionate to the crime. Graham at 59-60, quoting Harmelin v. Michigan, 501 U.S. 957, 1001, 111 S.Ct. 2680, 115 L.Ed.2d 836 (1991) (Kennedy, J., concurring). In capital cases, proportionality analysis involves two subsets, “one considering the nature of the offense, the other considering the characteristics of the offender.” Id. at 60. With respect to the nature of the offense, proportionality in capital cases merely stands for the proposition that the punishment must fit the crime. See, e.g., Kennedy v. Louisiana, 554 U.S. 407, 128 S.Ct. 2641, 171 L.Ed.2d 525 (2008) (<HOLDING>). {¶ 38} As for the second category, the United
holding that a death sentence for a conviction for the rape of a child where the crime did not result and was not intended to result in death of the victim was barred by the eighth amendment holding that the death penalty was categorically prohibited for juvenile offenders holding that an offenders death sentence for the rape of a child who did not die is unconstitutionally disproportionate holding a wrongful death action may not be maintained for the death of an unborn child holding the death penalty excessive punishment for the crime of rape